Summaries of recent legislative and regulatory developments with respect to: •SEC’s 2022 Examination Priorities • Proposed Amendments to Form PF Requirements- •Proposed New Rules Applicable to Private Fund Advisers and...more
The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue...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
The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more
The Commodity Futures Trading Commission published in the Federal Register on December 10, 2019 several amendments to the regulatory framework applicable to certain commodity pool operators (CPOs) and commodity trading...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
The Commodity Futures Trading Commission published in the Federal Register on December 10, 20191 amendments to five different aspects of the regulatory framework applicable to certain commodity pool operators (CPOs) and...more
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
• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more
BROKER-DEALER - FINRA Issues Report on Examination Findings - This month, the Financial Industry Regulatory Authority (FINRA) issued a report summarizing various findings from recent examinations of its member firms...more
The National Futures Association (NFA), the U.S. self-regulatory organization of the futures and swaps trading industry, has published a new Interpretive Notice entitled “Disclosure Requirements for NFA Members Engaging in...more
Introduction - The Commodity Futures Trading Commission (“CFTC”), the U.S. federal regulatory agency for futures and other derivatives, and the National Futures Association (“NFA”), the industry-wide self-regulatory...more
National Futures Association(NFA) is requiring that member commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) immediately notify NFA if they operate a pool or manage an account that engages in a...more
The Chicago Mercantile Exchange (CME) and the CBOE Futures Exchange (CFE) on December 1, 2017 self-certified contracts for bitcoin futures products with the U.S. Commodity Futures Trading Commission (CFTC). Additionally, on...more
During August 2016, the Commodity Futures Trading Commission (“CFTC” or “Commission”) and National Futures Association (“NFA”) published several items that will affect commodity pool operators (“CPO”) and commodity trading...more
The Commodity Futures Trading Commission (“CFTC”) on August 5, 2016, issued a proposal to amend its rules governing commodity pool annual reports, which, if adopted, would permit commodity pool operators (“CPOs”) of a pool...more
The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more
Any firm that is currently claiming certain exemptions or exclusions from registration with the Commodity Futures Trading Commission (CFTC) as a commodity pool operator (CPO) or commodity trading advisor (CTA) is required to...more
Investment Advisers - Annual Compliance Reviews: All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their...more
On November 5, 2015, the Commodity Futures Trading Commission (“CFTC”) Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued responses to frequently asked questions (“CFTC FAQs”) regarding CFTC Forms CPO-PQR and...more
Regulatory Developments: CFTC and NFA Staff Publish FAQs and Other Resources for Filing and Reporting on Forms CPO-PQR and CTA-PR - On Nov. 5 the Division of Swap Dealer and Intermediary Oversight of the CFTC...more
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
On Sept. 17, 2015, Commissioner Sharon Y. Bowen of the U.S. Commodity Futures Trading Commission (CFTC) gave the keynote address for the International Swaps and Derivatives Association’s 2015 North American Conference in New...more
The CFTC has adopted a rule, Rule 170.17, requiring all registered introducing brokers (IBs), commodity pool operators (CPOs) and certain commodity trading advisors (CTAs) to become a member of a registered futures...more
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