News & Analysis as of

Commodity Pool Operator › No-Action Letters

Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under... more +
Commodity Pool Operators are individuals who manage and secure capital for commodity pools. Most commodity pool operators are required to register as CPOs, unless they qualify for a registration exemption under the Commodity Futures Trading Commission regulations.  less -
Akin Gump Strauss Hauer & Feld LLP

CFTC Staff Extends Relief with Respect to Certain Position Limit Aggregation Requirements

Akin Gump Strauss Hauer & Feld LLP on

Key Points - Until August 12, 2025, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account...more

Alston & Bird

CFTC Issues No-Action Letter Offering Regulatory Relief for CPOs

Alston & Bird on

Our Investment Management Team outlines how the Commodity Futures Trading Commission will allow commodity pool operators to delay their reporting obligations during the coronavirus pandemic....more

Proskauer Rose LLP

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

Proskauer Rose LLP on

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

Broker-Dealer Compliance + Regulation

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

Broker-Dealer Compliance + Regulation on

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

Akin Gump Strauss Hauer & Feld LLP

CFTC Publishes Long-Awaited JOBS Act Relief

Akin Gump Strauss Hauer & Feld LLP on

The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more

Goodwin

CFTC Announces Streamlined Approach for Seeking Relief from Registration for Delegating Commodity Pool Operators

Goodwin on

The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) announced a streamlined approach for requesting relief from the commodity pool operator (“CPO”) registration requirement for a CPO that delegates...more

Proskauer Rose LLP

CFTC Announces Streamlined CPO Delegation Process

Proskauer Rose LLP on

On May 12, 2014, the Commodity Futures Trading Commission (CFTC) issued a no-action relief letter adopting a streamlined approach for commodity pool operator (CPO) delegation. The letter clarifies the conditions under which a...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Staff Announces Streamlined Process for CPO Delegation

Akin Gump Strauss Hauer & Feld LLP on

On March 12, 2014, the Commodity Futures Trading Commission (CFTC) staff issued the long-awaited guidance letter relating to the delegation of commodity pool operator (CPO) functions from persons that might otherwise be...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Staff Issues Long-Awaited CPO Delegation Relief"

Skadden, Arps, Slate, Meagher & Flom LLP on

On May 12, 2014, the Division of Swap Dealer and Intermediary Oversight (Division) of the Commodity Futures Trading Commission (CFTC) released its long-awaited commodity pool operator (CPO) delegation no-action letter...more

Goodwin

NFA Requires Notice Filing from Registered Fund CPOs Reporting on a Consolidated Basis for Registered Fund Pools and Their...

Goodwin on

The National Futures Association (the “NFA”) issued Notice to Members I-13-36 (the “NFA Notice”) which is directed at any commodity pool operator (“CPO”) of a registered investment company (a “RIC”) that has filed a notice...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters

Katten Muchin Rosenman LLP on

The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more

Orrick - Finance 20/20

CFTC No-Action Relief for Commodity Pools

Orrick - Finance 20/20 on

On April 2, the CFTC issued a time limited no-action letter that extended the deadline for compliance with reporting for commodity pool operators of securitization vehicles from March 31 until June 30....more

Miller & Martin PLLC

Family Office Relief from CPO Registration

Miller & Martin PLLC on

As noted in an earlier Client bulletin, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter dated November 29, 2012 enabling...more

Katten Muchin Rosenman LLP

CFTC Issues No-Action Letters

Katten Muchin Rosenman LLP on

The Commodity Futures Trading Commission (CFTC) released a series of staff letters relating to various issues arising under rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, including chief...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - December 14, 2012

Katten Muchin Rosenman LLP on

In this issue: - CFTC Issues No-Action Letters - SEC Division of Investment Management Lifts Actively-Managed ETF Derivatives Use Moratorium and Announces Two Rulemaking Initiatives - Antitrust “Tying” Claims...more

Orrick - Finance 20/20

CFTC No-Action Relief for Mortgage REIT Operators from Commodity Pool Operator Registration

Orrick - Finance 20/20 on

On December 7, the CFTC issued a no-action letter to mortgage real estate investment trusts which provides that the Division of Swap Dealer and Intermediary Oversight will not recommend that the CFTC take enforcement action...more

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