CPO, Commodity Trading Advisors (CTAs)

2020 Annual Compliance Obligation Reminders

Vedder Price on 2/11/2020

Investment advisers registered with the U.S. Securities and Exchange Commission (SEC) or with a state, as well as commodity pool operators and commodity trading advisors registered with the U.S. Commodity Futures Trading...more

NFA to Require Swap Proficiency Testing for Associated Persons of CPOs and CTAs Who Engage in Swaps Activity

Akin Gump Strauss Hauer & Feld LLP on 3/11/2019

• By January 31, 2021, all swap associated persons of registered CPOs and CTAs must take and pass the NFA’s new swaps proficiency requirements. • The swaps proficiency requirements mirror the proficiency testing long...more

CFTC Proposes to Codify Relief for CPOs and CTAs

K&L Gates LLP on 11/1/2018

Introduction - The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) is proposing amendments to its regulations governing commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) to codify...more

CFTC Proposes to Streamline CPO and CTA Regulations by Codifying Prior Relief

Proskauer Rose LLP on 10/24/2018

On October 9, 2018, the Commodity Futures Trading Commission (CFTC) proposed new rules in connection with the CFTC's Project KISS Initiative directed at simplifying Commodity Pool Operator (CPO) and Commodity Trading Advisor...more

CFTC Proposes to Streamline Regulations for Commodity Pool Operators and Commodity Trading Advisors

Orrick - Finance 20/20 on 10/18/2018

On October 9, the Commodity Futures Trading Commission (“CFTC“) unanimously approved proposed rules as a part of its KISS initiative to simplify regulations for commodity pool operators (“CPOs“) and commodity trading advisors...more

CFTC Proposes to Codify Existing Staff-Issued Relief from Registration and Other Compliance Requirements for CPOs and CTAs

Akin Gump Strauss Hauer & Feld LLP on 10/17/2018

• CPOs and CTAs of offshore commodity pools, family offices and business development companies would be exempt from registering with the CFTC. • Certain registered CPOs and CTAs would not be required to file Form CPO-PQR...more

A Light Lift: CFTC Proposes to Codify Existing No-Action Relief and Other Relief Applicable to CPOs and CTAs

Morgan Lewis on 10/12/2018

The US Commodity Futures Trading Commission has proposed a rule to streamline its regulation of commodity pool operators and commodity trading advisors, with most proposed amendments codifying, and in some cases broadening,...more

Federal Court Ruling Recognizes CFTC Jurisdiction over Cryptocurrencies as Commodities

Dechert LLP on 3/26/2018

The U.S. Commodity Futures Trading Commission (CFTC) scored a victory in its effort to assert jurisdiction over portions of the cryptocurrency and initial coin offering (ICO) markets last week, as a federal district judge...more

Affirmations of CPO and CTA registration exemptions are due by March 1, 2018

Eversheds Sutherland (US) LLP on 2/14/2018

Persons claiming exemptions from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA) must affirm their exemptions by March 1, 2018. Pursuant to Commodity Futures Trading Commission (CFTC)...more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

Dechert LLP on 1/24/2018

The U.S. federal securities laws and the rules of U.S. self regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

Financial Services Quarterly Report - Second Quarter 2017: U.S. CFTC Takes Steps to Modernize Rules and Operations and to Reduce...

Dechert LLP on 6/29/2017

Against a backdrop of changing markets, rapidly evolving technology and increased jurisdiction, the U.S. Commodity Futures Trading Commission (CFTC) – the regulatory agency with responsibility for oversight of the U.S....more

Financial Services Weekly News - December 2016

Goodwin on 12/7/2016

Editor's Note - OCC to Move Forward with Federal FinTech Charter. In a development foreshadowed in the April 6, June 29 and September 14 editions of the Roundup, on December 2, the Office of the Comptroller of the...more

NFA Proposal Would Require CFTC-Registered Asset Managers to Report on Financial Condition

Morgan Lewis on 9/16/2016

The National Futures Association’s (NFA’s) latest proposal would require registered commodity pool operators and commodity trading advisors to provide new information about their financial condition in quarterly reports to...more

CFTC Proposed Registration Relief for Non-U.S. Futures Commission Merchants, Commodity Pool Operators, Commodity Trading Advisors...

Broker-Dealer Compliance + Regulation on 8/8/2016

On July 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) proposed amendments to its rules (“Proposed Rules”) that loosen the conditions for exemption from registration as a futures commission merchant (“FCM”),...more

Deadline Approaches for Annual CPO/CTA Exemption Filings

Morgan Lewis on 1/12/2016

Firms must affirm their exemption or exclusion from CPO or CTA registration on the National Futures Association’s Exemption Filing System by February 29....more

U.S. House Votes to Reauthorize the CFTC and Exclude Most RICs from CPO and CTA Requirements

Broker-Dealer Compliance + Regulation on 6/30/2014

The U.S. House of Representatives on June 24, 2014, passed a version of the CFTC reauthorization bill, H.R. 4413, that would exclude investment advisers to registered investment companies (RICs) from the definitions of...more

NFA Issues Revised Forms CPO-PQR and CTA-PR

Eversheds Sutherland (US) LLP on 6/10/2014

On June 5, the National Futures Association (NFA) announced the issuance of revised Forms CPO-PQR and CTA-PR. The NFA is the self-regulatory organization to which the Commodity Futures Trading Commission (CFTC) has delegated...more

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

Goodwin on 2/19/2014

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

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