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Impact of Proposed Amendments to CFTC Regulation 4.7 on CPOs and CTAs

The US Commodities Futures Trading Commission (CFTC) recently proposed new rules that, among other actions, update the definition of a “qualified eligible person,” add minimum disclosure requirements for certain pools and...more

National Futures Association Proposes New Reporting Requirements for Commodity Pool Operators

The National Futures Association (NFA) has proposed a new rule that would require registered commodity pool operators (CPOs) that are members of the NFA (CPO Members) to report to the NFA by 5:00 pm Central Time the next...more

CFTC Streamlines Form CPO-PQR

The US Commodity Futures Trading Commission (CFTC or Commission) unanimously approved amendments to Form CPO-PQR on October 6 that will streamline the form beginning with the March 31, 2021 reporting period. Here is how the...more

CFTC Adopts Statutory Disqualification Requirement for Exempt CPOs

The Commodity Futures Trading Commission voted on June 4 to adopt rules prohibiting exempt commodity pool operators and their principals from operating commodity pools if they are subject to any of the statutory...more

CFTC Proposes Relief for Non-US Commodity Pool Operators

The US Commodity Futures Trading Commission has proposed amendments to CFTC Regulation 3.10(c)(3) to allow non-US commodity pool operators to claim an exemption from registration with respect to their offshore commodity pools...more

CFTC Proposes Streamlined Version of Form CPO-PQR

The Commodity Futures Trading Commission (CFTC) has proposed amendments to Form CPO-PQR, streamlining the form but requiring commodity pool operators (CPOs) to report legal entity identifiers to facilitate the CFTC’s data...more

DSIO Director Explains Thematic Commodity Pool Operator Swap Dealer Review Program

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

NFA Issues Internal Controls Guidance for Commodity Pool Operators

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

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

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

NFA Proposal Would Require CFTC-Registered Asset Managers to Report on Financial Condition

The National Futures Association’s (NFA’s) latest proposal would require registered commodity pool operators and commodity trading advisors to provide new information about their financial condition in quarterly reports to...more

CFTC Proposes Permanent Registration Relief to Certain Non-US Asset Managers

The amendments to the CFTC’s registration rules will codify no-action relief that permits non-US asset managers to rely on an exemption from the requirement to register with the CFTC by virtue of trading uncleared swaps in...more

CFTC Staff Exempts Certain Commodity Trading Advisors from Form CTA-PR Reporting

The reporting relief applies to commodity trading advisors that do not “direct” trading of any client commodity interest trading accounts. On July 23, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued...more

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