News & Analysis as of April 30, 2025

Commodities Futures Trading Commission

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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 +

Cole-Frieman & Mallon partner/co-founder Bart Mallon Discusses CFTC Regulation 4.5, the Volcker Rule & Other Compliance Issues

The deadline for re-affirming CPO exemptions/exclusions is approaching

Eversheds Sutherland (US) LLP on 2/14/2025

Under Commodity Futures Trading Commission (CFTC) regulations, persons who have claimed an exemption or exception from commodity pool operator (CPO) or commodity trading advisor (CTA) status pursuant to Part 4 of the CFTC’s...more

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

Akin Gump Strauss Hauer & Feld LLP on 4/16/2020

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

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 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

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

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

Dechert LLP on 10/1/2014

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

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

Katten Muchin Rosenman LLP on 9/16/2014

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

CFTC Publishes Long-Awaited JOBS Act Relief

Akin Gump Strauss Hauer & Feld LLP on 9/12/2014

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

Year-End CFTC Reporting Requirements for Fund Advisers

Broker-Dealer Compliance + Regulation on 12/12/2013

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

Orrick, Herrington & Sutcliffe LLP on 11/12/2013

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

Disclosure Requirements and Advertising Rules for CPOs

Morrison & Foerster LLP on 9/23/2013

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

Corporate and Financial Weekly Digest - August 16, 2013

Katten Muchin Rosenman LLP on 8/19/2013

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

NFA Amends CPO and CTA Quarterly Reporting Requirements

Katten Muchin Rosenman LLP on 4/30/2013

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

CFTC No-Action Relief for Commodity Pools

Orrick - Finance 20/20 on 4/9/2013

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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