News & Analysis as of

Commodity Pool Operator › No-Action Relief

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

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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

K&L Gates LLP

CFTC Permits Unaudited Financial Statements Upon Liquidation of a Series of a Pool That is Also a Registered Investment Company

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The Commodity Futures Trading Commission (“CFTC” or “Commission”) has provided general exemptive relief to persons registered as commodity pool operators (“CPO”) under the Commodity Exchange Act that operate commodity pools...more

Orrick - Finance 20/20

CFTC Staff Announces Self-Executing Registration No-Action Relief for Delegating CPOs

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On October 15, CFTC Division of Swap Dealer and Intermediary Oversight (DSIO) announced that it is providing self-executing registration no-action relief for certain commodity pool operators (CPOs) who delegate certain...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 23

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In this issue: - SEC Chair Gives Speech on Equity Market Structure - New CFTC Commissioners Confirmed; Chairman Sworn In - CFTC Extends No-Action Relief for Certain Transaction-Level Requirements...more

K&L Gates LLP

CFTC Provides Streamlined No-Action Relief Filing Procedure to Certain Commodity Pool Operators Who Delegate Responsibilities to...

K&L Gates LLP on

The Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or the “Commission”) recently issued CFTC Letter No. 14-69 (May 12, 2014) (the “Letter”), which...more

Katten Muchin Rosenman LLP

CFTC Staff Announces Streamlined No-Action Relief Process for Certain CPOs

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On May 12, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight announced a streamlined process that will allow a commodity pool operator (CPO) that has delegated investment management...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

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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

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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 Grants Relief to CPOs Trading Through Subsidiaries

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The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has granted no-action relief from certain reporting obligations to commodity pool operators (CPOs) of registered investment...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - September 13, 2013

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In this issue - - Federal Agencies Seek Comment on Joint Proposed Rule Regarding Credit Risk Retention - SEC Grants Request for No-Action Relief with Respect to Multi-Day Pre-Fail and Post-Fail Credit Under Rule...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - December 21, 2012

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In this issue: - Nallengara to Replace Cross as Corp. Fin. Chief - FINRA Rule Relating to Private Placements of Securities Effective December 3 - Additional Guidance on FINRA’s Suitability Rule - No-Action...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review - December 17, 2012

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In This Issue: *Financial Industry Developments - CFTC No-Action Relief for Securitizations from Commodity Pool Operator Registration - CFTC No-Action Relief for Mortgage REIT Operators from Commodity Pool...more

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