On December 19, 2025, the Market Participants Division (“MPD”) of the Commodities Futures Trading Commission (“CFTC”) issued No-Action Letter No. 25-50, granting interim relief for certain commodity pool operators (“CPOs”)...more
On December 19, 2025, the Market Participants Division (MPD) of the U.S. Commodity Futures Trading Commission (CFTC) issued a no-action letter (Letter) providing certain private fund managers with temporary relief from the...more
The staff of the Market Participants Division (the “Staff”) of the Commodity Futures Trading Commission (CFTC) have issued two no-action letters that provide targeted relief from commodity pool operator (CPO) and commodity...more
On Dec. 19, 2025, the Market Participants Division (MPD) of the Commodity Futures Trading Commission (CFTC) issued No-Action Letter 25-50 (the “Letter”), which provides interim no-action relief from commodity pool operator...more
In December 2025, the Staff of the U.S. Commodities Futures Trading Commission (“CFTC”) issued a no-action letter (the “Letter”) that effectively reinstates the former Rule 4.13(a)(4) exemption from registration as commodity...more
On December 19, 2025, the Market Participants Division (MPD) of the CFTC published CFTC Letter No. 25-50, issuing interim relief in response to a request from the Managed Funds Association....more
On December 19, 2025, the Staff of the Commodity Futures Trading Commission (CFTC) issued no-action relief that effectively reinstates (with a few modifications) an exemption from registration for commodity pool operators...more
The Commodity Futures Trading Commission’s new no-action relief creates a temporary pathway for certain private fund managers to avoid or de-register from commodity pool operator (CPO) registration. Our Investment Funds Team...more
Dorsey’s 2026 Private Funds Compliance Calendar addresses certain key regulatory obligations that apply to private funds and private fund advisers....more
On Friday, December 19, the Staff of the Commodity Futures Trading Commission’s (CFTC) Markets Participant Division published a new no-action letter – CFTC Staff Letter 25-50 – which creates an exemption from commodity pool...more
On December 19, 2025, one day after the U.S. Senate confirmed Michael Selig as the new Chairman of the Commodity Futures Trading Commission (the “CFTC”), the staff of the Market Participants Division (the “Division”) of the...more
Consistent with the ongoing trend towards deregulation of the investment management industry in the United States, the Commodity Futures Trading Commission (CFTC) Market Participants Division (MPD) issued a no-action letter...more
The regulatory framework governing the intersection of derivatives markets and the private fund industry has reached a pivotal inflection point. On December 19, 2025, the Market Participants Division of the Commodity Futures...more
On September 17, 2025, the SEC and the CFTC voted to extend the compliance date for amendments to Form PF for a third time, resulting in a new compliance date of October 1, 2026. Form PF is the confidential reporting form...more
As of 12:01 am on October 1, 2025, congressionally appropriated funding lapsed for most operations of the United States government. Though the government has shut down, business continues, and market participants that need to...more
Private credit continues to assume mandates once dominated by banks, fueled by insurer capital and bank-provided facilities. Regulators in the United States and European Union are intensifying their scrutiny of funding...more
On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more
On June 11, 2025 the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) again extended the compliance date for the most recent Form PF amendments, providing a near four-month reprieve for...more
Since our prior IM Update, in separate Alerts, we covered (i) the SEC’s decision to remove from its regulatory agenda proposed rulemakings relevant to the investment management industry, (ii) Ropes & Gray’s updated and...more
On June 11, 2025, the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have once again delayed the compliance date for the amendments to Form PF, moving it to October 1, 2025....more
On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the amendments to Form PF that were adopted on February 8, 2024. The compliance date for these amendments, which was...more
On June 11th, 2025, the Securities and Exchange Commission (the “SEC”), together with the U.S. Commodity Futures Trading Commission (the “CFTC”) further extended the compliance date for the amendments to Form PF (the “Form PF...more
On June 11, 2025, the Securities and Exchange Commission and the Commodity Futures Trading Commission voted to extend the compliance date of the Form PF amendments that were adopted in February 2024 again from June 12, 2025...more
Yesterday, the Securities and Exchange Commission (SEC) voted to extend the compliance date for rule amendments that expand the reporting requirements for private fund managers. The Form PF amendments were adopted on February...more
On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025....more