On December 18, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a letter granting relief from commodity pool operator (CPO) registration to certain entities...more
The CFTC previously granted family offices no-action relief from registration as commodity pool operators. That letter did not provide an exemption from registration as a commodity trading advisor. However, the CFTC has...more
The staff of the Commodity Futures Trading Commission (CFTC) yesterday changed its position and no longer requires a no-action request for delegation of commodity pool operator (CPO) functions from persons that might...more
The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) announced a streamlined approach for requesting relief from the commodity pool operator (“CPO”) registration requirement for a CPO that delegates...more
On May 12, 2014, the Commodity Futures Trading Commission (CFTC) issued a no-action relief letter adopting a streamlined approach for commodity pool operator (CPO) delegation. The letter clarifies the conditions under which a...more
In this issue: - SEC Division of Corporation Finance Issues Guidance on Rule 506(c) Private Placements - SEC Issues No-action Relief Regarding Registration of M&A Brokers - CFTC Issues Guidance on New...more
As the date for compliance with swap execution facility (SEF) registration requirements approached, the Commodity Futures Trading Commission (the CFTC or Commission) issued a number of no-action letters and interpretive...more