News & Analysis as of

Registration Commodities Futures Trading Commission Commodity Pool Operator

Eversheds Sutherland (US) LLP

NFA Issues Revised Forms CPO-PQR and CTA-PR

On June 5, the National Futures Association (NFA) announced the issuance of revised Forms CPO-PQR and CTA-PR. The NFA is the self-regulatory organization to which the Commodity Futures Trading Commission (CFTC) has delegated...more

Goodwin

CFTC Announces Streamlined Approach for Seeking Relief from Registration for Delegating Commodity Pool Operators

Goodwin on

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

Proskauer Rose LLP

CFTC Announces Streamlined CPO Delegation Process

Proskauer Rose LLP on

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

Goodwin

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

Goodwin on

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

Goodwin

NFA Issues Guidance on Annual Affirmation Requirement for Entities Operating Under An Exemption or Exclusion from CPO or CTA...

Goodwin on

The National Futures Association (the “NFA”) has issued guidance reminding market participants of CFTC regulations that require any person claiming an exemption or exclusion under CFTC Regulation 4.5, 4.13(a)(1), 4.13 (a)(2),...more

Goodwin

CFTC Proposes Rule to Require All Registered Introducing Brokers, Commodity Pool Operators, and Commodity Trading Advisors to be...

Goodwin on

The CFTC has proposed a rule that would require all registered introducing brokers (“IBs”), commodity pool operators (“CPOs”), and commodity trading advisors (“CTAs”) to be members of a registered futures association (“RFA”)....more

Katten Muchin Rosenman LLP

CFTC Proposes Rules to Require that IBs, CPOs and CTAs Become Members of a Registered Futures Association

The Commodity Futures Trading Commission has proposed rules requiring that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors (CTAs) become members of at least one...more

Katten Muchin Rosenman LLP

CFTC Adopts Final Harmonization Rules for Registered Investment Company Advisors Required to Register as CPOs Under 4.5; Also...

On August 13, 2013, the Commodity Futures Trading Commission issued its final rules ("Final Rules") applicable to registered investment companies whose advisers are now required to dually register as commodity pool operators...more

Katten Muchin Rosenman LLP

CFTC Adopts Final Harmonization Rules for Registered Investment Company Advisers Required to Register as CPOs Under Regulation...

On August 13, 2013, the Commodity Futures Trading Commission issued its final rules (“Final Rules”) applicable to registered investment companies now required to dually register as commodity pool operators (“Dually-Registered...more

Troutman Pepper

CFTC Adopts Final Harmonization Rules For Registered Investment Companies Dually Registered As Commodity Pool Operators

Troutman Pepper on

Eighteen months after amending CFTC Regulation 4.5 to narrow the registered investment company (RIC) exclusion from the definition of commodity pool operator (CPO) and issuing a companion release proposing to amend certain...more

BakerHostetler

D.C. Circuit Court Upholds Dodd-Frank Inspired CFTC Regulations Subjecting Mutual Funds That Invest in Commodities to CFTC...

BakerHostetler on

In 2012, the Commodity Futures Trading Commission (CFTC), in response to Dodd-Frank, adopted new regulations to require mutual funds and other registered investment companies that exceed certain position levels in commodity...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters

The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more

Miller & Martin PLLC

Family Office Relief from CPO Registration

Miller & Martin PLLC on

As noted in an earlier Client bulletin, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter dated November 29, 2012 enabling...more

Katten Muchin Rosenman LLP

NFA to Require CPOs to Identify Registered Investment Companies

The National Futures Association (NFA) has notified its members that it will require each member of the NFA that is registered as a commodity pool operator (CPO) and operates one or more commodity pools that are also...more

Katten Muchin Rosenman LLP

NFA Provides Bylaw 1101 Guidance to Commodity Pool Operators of Investment Companies

Under amended Commodity Futures Trading Commission Regulation 4.5, registered investment advisers (RIAs) to registered investment companies engaging in more than minimal commodity trading activities will be required to...more

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