News & Analysis as of

CPOs Recordkeeping Requirements

Dechert LLP

NFA Institutes New Operational Requirements for Members; Registered CPOs and CTAs Need to Take Action in Q3 and Q4 2021

Dechert LLP on

The National Futures Association has adopted two new operational requirements that will affect (among others) registered commodity pool operators and commodity trading advisors. Under new NFA Compliance Rule 2-50, as of...more

Perkins Coie

Statement of DSIO Director Joshua B. Sterling on Supporting Innovation in Digital Asset Products, including Pooled Investment...

Perkins Coie on

The CFTC DSIO Division Director issued a statement reminding the industry that pooled investment vehicles that trade futures, swaps, and other commodity interests that reference digital assets like Bitcoin and stablecoins are...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

Akin Gump Strauss Hauer & Feld LLP

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

• 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

Dechert LLP

NFA Adopts Cybersecurity Guidance

Dechert LLP on

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

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 49

In this issue: - Delaware Chancery Court Declines to Dismiss Fraud Claims Against Private Equity Fund and Directors - Agencies Amend Regulatory Capital and Liquidity Coverage Ratio Rules - FINRA Proposes...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Staff Issues More No-Action Letters to Commodity Pool Operators"

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

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