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Futures Commission Merchants (FCMs) Investment Management

Blank Rome LLP

Part 2: Separate Accounts in the Investment Management Context

Blank Rome LLP on

This is the third of a multi-part series (Introduction; Part 1) on a February 20 proposal by the U.S. Commodity Futures Trading Commission (“CFTC”) to implement CFTC Regulation §1.44 (the “Proposed Rule”) and related...more

WilmerHale

New Joint Audit Committee Regulatory Alerts

WilmerHale on

On May 14, 2019, the Joint Audit Committee (JAC) issued two regulatory alerts calling for futures commission merchants (FCMs) to review policies and procedures and account agreements in situations where an FCM carries...more

Akin Gump Strauss Hauer & Feld LLP

Supplemental Proposal to Regulation AT: What Investment Managers Need to Know

Key Points - - The supplemental proposed rulemaking to Regulation AT heightens the procedural mechanisms by which source code is made accessible to the CFTC. - The supplemental proposed rulemaking adds a...more

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