News & Analysis as of

Commodity Pool Operator › Reporting Requirements

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 Proposes to Narrow its CPO-PQR to Conform to the NFA Form PQR and Add LEIs

Akin Gump Strauss Hauer & Feld LLP on

On April 14, 2020, the Commodity Futures Trading Commission (CFTC) proposed, among other things, to narrow and revise the scope of information that it collects from commodity pool operators (CPOs) on its Form CPO-PQR to: ...more

K&L Gates LLP

CFTC Proposes to Codify Relief for CPOs and CTAs

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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

Akin Gump Strauss Hauer & Feld LLP

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

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• 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

Dechert LLP

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

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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

Akin Gump Strauss Hauer & Feld LLP

2015-16 Compliance Developments & Calendar for Private Fund Advisers

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Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more

BakerHostetler

CA AG Requires Chief Privacy Officer and Privacy Compliance Program

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California’s Attorney General, Kamala Harris, has required Houzz, a home décor information and e-commerce website and mobile app publisher, to hire a chief privacy officer (CPO), conduct a company-wide privacy assessment, and...more

Akin Gump Strauss Hauer & Feld LLP

2014-15 Compliance Developments & Calendar for Private Fund Advisers

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Introduction - Registered investment advisers are required to review their policies and procedures on at least an annual basis. As aid to the required review, below is a summary of material developments during the past...more

Dechert LLP

CFTC Issues Exemptive Relief Related to JOBS Act Amendments to Regulation D

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The Division of Swap Dealer and Intermediary Oversight (Division) of the U.S. Commodity Futures Trading Commission (CFTC) on September 9, 2014 issued a letter granting exemptive relief from provisions in CFTC Regulations...more

Katten Muchin Rosenman LLP

CFTC Aligns CPO Regulation With JOBS Act, Provides Other Guidance for CPOs

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The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) recently issued several letters affecting commodity pool operators (CPOs): JOBS Act Harmonization: On September 9,...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Publishes Long-Awaited JOBS Act Relief

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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

Broker-Dealer Compliance + Regulation

Year-End CFTC Reporting Requirements for Fund Advisers

Broker-Dealer Compliance + Regulation on

The National Futures Association (NFA) reminded fund advisers claiming an exemption from registering as a commodity pool operator (CPO) that they must confirm by March 3, 2014 that will continue to rely on the exemption....more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review - November 12, 2013

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CFTC Proposed Rule on Commodity Pools - On November 5, the CFTC issued a proposed rule that would require that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors...more

Morrison & Foerster LLP

Disclosure Requirements and Advertising Rules for CPOs

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On August 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) adopted final rule amendments to accept compliance with the disclosure, reporting and recordkeeping rules of the Securities and Exchange Commission...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - August 16, 2013

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In this issue: - SEC Issues Risk Alert on Options Trading Used to Evade Short-Sale Requirements - SEC Order Temporarily Exempting Certain Broker Dealers and Certain Transactions from the Recordkeeping and...more

Katten Muchin Rosenman LLP

NFA Amends CPO and CTA Quarterly Reporting Requirements

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On April 24, the National Futures Association (NFA) issued a notice to members regarding amendments to NFA Compliance Rule 2-46. The amended rule modifies the NFA’s quarterly pool reporting requirements and extends related...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - April 26, 2013

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In this issue: - NFA Amends CPO and CTA Quarterly Reporting Requirements - SDNY Imposes Second Highest Penalty Under Foreign Corrupt Practices Act - Grand Jury Indicts Swiss Lawyer and Banker in Tax...more

Orrick - Finance 20/20

CFTC No-Action Relief for Commodity Pools

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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

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