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
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
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 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
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
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
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