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CPOs Commodities Futures Trading Commission National Futures Association

Akin Gump Strauss Hauer & Feld LLP

CFTC Adopts Bad Actor Disqualifications for CPO Exemptions

- A CPO will be prohibited from claiming an exemption from registration under CFTC Regulation 4.13 if it or any of its principals has in their backgrounds a statutory disqualification under the Commodity Exchange Act. - A...more

Latham & Watkins LLP

A CFTC Helping Hand: DSIO Offers to Review Digital Asset Products

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Product innovation (including in pooled investment vehicles) is encouraged, but innovation must be consistent with the law. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary...more

Eversheds Sutherland (US) LLP

BDCs must reclaim relief from CPO registration

On November 25, 2019, the Commodity Futures Trading Commission (CFTC) adopted several final regulations to codify existing exemptions from commodity pool operator (CPO) registration. Among them is an exemption that was issued...more

K&L Gates LLP

CFTC and SEC Issue Privacy Guidance

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CFTC Proposes New Swap Data Reporting Requirements and NFA Proposes Dues Surcharge for Swap Firms - INTRODUCTION - The Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”)...more

K&L Gates LLP

Swaps Proficiency Requirements for Associated Persons; Revised Form 7-R

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Introduction - By a Notice to Members dated March 25, 2019, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, announced that it had amended rules and adopted an...more

Foley Hoag LLP

April 1, 2019: Effective Date of NFA Compliance Rule 2-9

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As a reminder, pursuant to an Interpretive Notice recently released by the National Futures Association (“NFA”), all commodity pool operators (“CPOs”) that are registered with the U.S. Commodity Futures Trading Commission...more

Dechert LLP

NFA Amends its Information System Security Program Requirements; CFTC-Registered CPOs and CTAs Need to Take Action by April 1

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The National Futures Association (NFA), the self-regulatory organization of the futures and swap trading industry, announced to its membership on January 7, 2019 that it had amended its requirements for NFA Member Information...more

K&L Gates LLP

NFA Proposes Interpretive Notice Addressing CPO Internal Controls

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Introduction - By letter dated December 10, 2018, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, submitted to the U.S. Commodity Futures Trading Commission...more

Katten Muchin Rosenman LLP

Bridging the Week - December 2018

A federal judge said that it is not a violation of federal law for a trading firm and its chief executive officer to be smarter than their counterparties in ruling against the Commodity Futures Trading Commission in an...more

Latham & Watkins LLP

Effective October 31, 2018: New NFA Virtual Currency Disclosure Requirements

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The NFA will soon require CPO, CTA, FCM, and IB member firms to provide various disclosures warning investors of virtual currency spot and derivatives trading risks. New disclosure requirements warning customers,...more

Dechert LLP

NFA Adopts Cybersecurity Guidance

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The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

Broker-Dealer Compliance + Regulation

CFTC Requires Introducing Brokers, Commodity Pool Operators, and Most Commodity Trading Advisors That Use Swaps to Become Members...

On September 14, 2015, the Commodity Futures Trading Commission (CFTC) published a final rule requiring introducing brokers (IBs), commodity pool operators (CPOs), and most commodity trading advisors (CTAs) to become members...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Extends Registered Futures Association Membership Requirement to Introducing Brokers, Commodity Pool Operators and Commodity...

The Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule (“Final Rule”) that formally extends the existing registered futures association (“RFA”) membership requirement to registered introducing...more

K&L Gates LLP

Cybersecurity Update: National Futures Association Proposes Cybersecurity Guidance Setting Forth General Requirements for Member...

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The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more

Katten Muchin Rosenman LLP

NFA Requires Notice From CPOs that Consolidate Filings of Subsidiary Pools

National Futures Association (NFA) has issued a notice requiring all commodity pool operators (CPOs) that have filed a notice of claim under Commodity Futures Trading Commission Letter No. 14-112 to submit an additional...more

K&L Gates LLP

NFA Requires Delegated CPOs to Identify Themselves

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The National Futures Association (“NFA”) issued a Notice to Members on April 8, 2015 that requires “Delegated CPOs” to identify themselves as such when filing a commodity pool’s annual financial statement. Registered...more

Goodwin

Financial Services Weekly News Roundup - January 2015 #3

Goodwin on

Editor’s Note - The Supreme Court Halts Challenge by Retailers to the Debit Card Interchange Fee Rules: On January 20, 2015, the Supreme Court denied certiorari to a challenge by retailers to debit card interchange fee...more

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