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
On October 18, 2018, the Commodity Futures Trading Commission (CFTC) published a proposal in the Federal Register (Proposed Rule) to amend several key compliance and registration regulations governing commodity pool operators...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
The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has granted no-action relief to certain intermediaries located outside the United States. As background, CFTC Regulation...more
No-action relief confirms that non-US asset managers may rely on an exemption from CFTC registration when trading uncleared swaps in the United States for the accounts of their non-US clients, an issue that had been in doubt...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
In November and December 2014, the Commodity Futures Trading Commission (the “CFTC”) and Securities and Exchange Commission (“SEC”), respectively, issued guidance regarding the applicability of certain regulations to family...more
Toward the end of 2014, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued two letters affecting insurance-linked securitization vehicles: CFTC...more
On December 18, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a letter granting relief from commodity pool operator (CPO) registration to certain entities...more
The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) recently issued no-action relief for failure to register with the CFTC as a commodity trading advisor (CTA) to any...more
The CFTC previously granted family offices no-action relief from registration as commodity pool operators. That letter did not provide an exemption from registration as a commodity trading advisor. However, the CFTC has...more
Over the last month, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) issued four letters providing exemptive, no-action and interpretative relief to commodity...more
Editor’s Note: Bank Regulators Again Looking at Incentive Compensation and Excessive Risks. Federal Reserve Board Governor Daniel Tarullo and New York Federal Reserve President William Dudley spoke on October 20 at a...more
High-Frequency Trading Firm Pays US $1 Million for Serving Too Much “Gravy” on the Close From June to December 2009 - Athena Capital Research, LLC, a New York City-based high-frequency trading firm, settled charges...more
On October 15, 2014, the Commodity Futures Trading Commission (CFTC) issued a no-action relief letter granting self-executing registration no-action relief to qualifying commodity pool operators (CPOs) that delegate their CPO...more
The staff of the Commodity Futures Trading Commission (CFTC) yesterday changed its position and no longer requires a no-action request for delegation of commodity pool operator (CPO) functions from persons that might...more
In May, the Commodity Futures Trading Commission (CFTC) staff announced a streamlined process that allows persons seeking no-action relief to avoid registering as commodity pool operators (CPOs). They must, however, designate...more