The Commodity Futures Trading Commission (CFTC) recently adopted a final rule amending CFTC Rule 4.7. CFTC Rule 4.7 provides an exemption from certain disclosure, recordkeeping and reporting requirements for registered...more
The CFTC has finalized portions of its proposed October 2023 amendments to CFTC Rule 4.7. The CFTC moved forward on: Raising the thresholds for qualification of certain investors in private funds commodity pool operators...more
On September 12, the Commodity Futures Trading Commission (CFTC or Commission) published a final rule, adopting amendments to CFTC Rule 4.7, which provides exemptive relief from certain compliance obligations to registered...more
On September 29, 2023, the CFTC approved a proposal to amend certain provisions of its regulations relating to commodity pools, specifically Rule 4.7. The proposal would be the first major change to Rule 4.7 in over 30...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
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
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
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
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
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
The National Futures Association (NFA) issued a notice on August 9, 2018, to its members announcing that new disclosures relating to virtual currencies and virtual currency derivatives will be required of NFA members that...more
The National Futures Association (NFA) announced the effective date of its interpretive notice that establishes virtual currency disclosure requirements applicable to futures commission merchant, introducing broker, commodity...more
Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more
SEC/CORPORATE - Implementation of Pay Ratio Disclosure Requirement Not Expected to Be Delayed - On September 15, at the ABA Business Law Section Annual Meeting, the Securities and Exchange Commission (SEC) Division of...more
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