Our Investment Funds Group examines how the Commodity Futures Trading Commission (CFTC) has amended Regulation 4.7 to increase investor suitability standards and provide additional flexibility for funds-of-funds reporting....more
The Commodity Futures Trading Commission (Commission or CFTC) voted to announce proposed rule changes on October 2, 2023, that would significantly change the disclosure requirements applicable to registered commodity pool...more
The Commodity Futures Trading Commission, on December 7, 2020, published in the Federal Register significant amendments to CFTC Regulation 3.10(c) (Amendments), making the regulation a more broadly available registration...more
The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more
• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more
Director Joshua B. Sterling of the CFTC’s Division of Swap Dealer and Intermediary Oversight (DSIO or Division) delivered several speeches in September and early October 2019, setting forth certain guiding principles and the...more
The amendments to the CFTC’s registration rules will codify no-action relief that permits non-US asset managers to rely on an exemption from the requirement to register with the CFTC by virtue of trading uncleared swaps in...more
On November 5, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission published responses (Responses) to frequently asked questions regarding Forms CPO-PQR and CTA-PR (Forms). The...more
In seeking comment on potential risks to the U.S. financial system created by asset managers, the Financial Stability Oversight Council (FSOC) again places asset managers in its crosshairs. This crusade potentially can lead...more
Regulatory Developments - SEC Proposes Changes to Exchange Act Registration Requirements to Implement JOBS Act Mandates - The SEC announced that it is proposing rule amendments under the Securities Exchange Act...more