News & Analysis as of

CPOs Commodities

Holland & Knight LLP

CFTC Seeks Comments on Use of AI in Derivatives Markets

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The Commodity Futures Trading Commission (CFTC) has issued a request for comment (RFC) seeking public input on the use of artificial intelligence (AI) in CFTC-regulated markets. The RFC – distributed jointly by the CFTC's...more

Fox Rothschild LLP

Updated 2023– Who Does What: Broker Dealers | Registered Investment Advisers | Commodities/Futures Entities

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I. Starting a Broker-Dealer- Becoming an owner of a broker-dealer (BD) is a time-consuming and expensive endeavor. Although the United States Securities and Exchange Commission (SEC) requires BD registration pursuant to the...more

Dechert LLP

CFTC Finalizes New Requirement Applying Statutory Disqualification Prohibitions to CPOs Exempt under CFTC Regulation 4.13 – Exempt...

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CFTC Also Proposes Amendments to Help Non-U.S. CPOs and Extends its Uncleared Swap Margin Phase-In Schedule - During the period from late May 2020 through early June 2020, the Commodity Futures Trading Commission held...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Proposes to Expand Availability of 3.10(c)(3) Registration Exemption for Non-U.S. Commodity Pool Operators

Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides that non-U.S. commodity pool operators (CPOs) are exempt from registration if they solely operate non-U.S. commodity pools offered to...more

Cadwalader, Wickersham & Taft LLP

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

Dechert LLP

SEC Proposes Rule Changes Applicable to BDCs’ Use of Derivatives and Other Transactions

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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

Dechert LLP

New NFA Filing Obligations for Investment Advisers to BDCs Trading Commodity Interests Require Action as Soon as Practicable After...

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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

Dechert LLP

New CFTC DSIO Director Outlines Components of Regulatory Program Applicable to Asset Managers; Addresses Extension of the CFTC...

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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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes to Simplify, Modernize Commodity Pool Operator and Commodity Trading Advisor Regulations

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

Dechert LLP

CFTC Proposes Amendments to Regulatory Framework for Certain CPOs and CTAs and New Exemption for CPOs of Non-U.S. Pools

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The Commodity Futures Trading Commission issued a Notice of Proposed Rulemaking on October 9, 2018 to amend certain aspects of the current regulatory framework applicable to commodity pool operators (CPOs) and commodity...more

Mayer Brown Free Writings + Perspectives

CPO and CTA Rule Proposals

Earlier this month, the Commodity Futures Trading Commission proposed rules that would codify certain relief provided to commodity pool operators and commodity trading advisors in the post Dodd-Frank Act years....more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on CFTC Proposed CPO and CTA Regulations, Brexit Statutory Instruments and...

CFTC - CFTC Approves Proposed Regulations for CPOs and CTAs - On October 9, the Commodity Futures Trading Commission approved proposed rules intended to simplify regulations for commodity pool operators (CPOs) and...more

Kramer Levin Naftalis & Frankel LLP

New Disclosure Rules Enhance Crypto Investor Protection

Amid concerns that many investors may not fully understand the risks associated with virtual currencies, or the limits of regulatory oversight, the National Futures Association (NFA) recently issued an interpretive notice...more

Dechert LLP

Bitcoin Futures Trading Commences; Implications for Funds and Registered CPOs and CTAs

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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

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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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

Katten Muchin Rosenman LLP

CFTC Provides Additional Relief to Certain Delegating CPOs

In response to industry comment, on October 15 the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) provided further relief from commodity pool operator (CPO) registration to a...more

Dechert LLP

CFTC Staff Issues Self-Executing CPO Delegation Relief

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The staff of the Commodity Futures Trading Commission (CFTC Staff) on October 15, 2014 simplified the process for a natural person or entity that the CFTC considers to be a commodity pool operator (CPO) to delegate its CPO...more

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