News & Analysis as of

Investment Management Commodity Pool

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 at the state level are required to review their compliance policies and...more

Akin Gump Strauss Hauer & Feld LLP

New Outsourced Compliance Guidance – Implications for CFTC-Registered Private Fund Managers

Key Point - As of September 30, 2021, private fund managers registered with the CFTC as CPOs or CTAs will be required, under new NFA guidance, to supervise certain third-parties performing regulatory functions. ...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Expands Availability of 3.10(c)(3) Registration Exemption for Non-US Commodity Pool Operators and Commodity Trading Advisors

Commodity Futures Trading Commission (CFTC) Regulation 3.10(c)(3) currently provides an exemption from registration for non-U.S. commodity pool operators (CPOs) and commodity trading advisors (CTAs), if they solely operate...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Adopts Bad Actor Disqualifications for CPO Exemptions

- A CPO will be prohibited from claiming an exemption from registration under CFTC Regulation 4.13 if it or any of its principals has in their backgrounds a statutory disqualification under the Commodity Exchange Act. - A...more

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Morgan Lewis

DSIO Director Explains Thematic Commodity Pool Operator Swap Dealer Review Program

Morgan Lewis on

In late September, the director of the Division of Swap Dealer and Intermediary Oversight (DSIO) of the US Commodity Futures Trading Commission (CFTC), Joshua Sterling, announced a new examination program for commodity pool...more

Foley Hoag LLP

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

Foley Hoag LLP on

Investment Advisers - Annual Compliance Reviews - All investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - January 2019

Dechert LLP on

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...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

Morgan Lewis

NFA Issues Internal Controls Guidance for Commodity Pool Operators

Morgan Lewis on

The National Futures Association (NFA) recently proposed an interpretive notice that would require members that are commodity pool operators (CPOs) to adopt and implement internal controls systems designed to deter fraudulent...more

Morgan Lewis

A Light Lift: CFTC Proposes to Codify Existing No-Action Relief and Other Relief Applicable to CPOs and CTAs

Morgan Lewis on

The US Commodity Futures Trading Commission has proposed a rule to streamline its regulation of commodity pool operators and commodity trading advisors, with most proposed amendments codifying, and in some cases broadening,...more

Akin Gump Strauss Hauer & Feld LLP

NFA Inspects Hong Kong Based Investment Managers

The U.S. National Futures Association (NFA) has confirmed that it has commenced its first-ever, on-site inspection program of NFA member firms located in Hong Kong. Prior to this current initiative, the NFA’s inspections of...more

Troutman Pepper

Treasury Report Addresses Regulatory Approaches Affecting Investment Companies and Their Advisers

Troutman Pepper on

As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more

K&L Gates LLP

Cybersecurity Update: National Futures Association Proposes Cybersecurity Guidance Setting Forth General Requirements for Member...

K&L Gates LLP on

The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more

Foley Hoag LLP

Reminder: Upcoming Deadlines for Clearing Requirements for Certain Swaps

Foley Hoag LLP on

Investment managers who use swaps on behalf of their clients (including funds) are reminded that the phase-in for mandatory clearing of certain types of swaps has begun. Investment managers should be analyzing (a) the types...more

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