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Recordkeeping Requirements Commodity Trading Advisors (CTAs)

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

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On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Dechert LLP

NFA Institutes New Operational Requirements for Members; Registered CPOs and CTAs Need to Take Action in Q3 and Q4 2021

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The National Futures Association has adopted two new operational requirements that will affect (among others) registered commodity pool operators and commodity trading advisors. Under new NFA Compliance Rule 2-50, as of...more

Dechert LLP

SEC Proposes Rule Changes Applicable to BDCs’ Use of Derivatives and Other Transactions

Dechert LLP on

The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Proposes to Codify Existing Staff-Issued Relief from Registration and Other Compliance Requirements for CPOs and CTAs

• CPOs and CTAs of offshore commodity pools, family offices and business development companies would be exempt from registering with the CFTC. • Certain registered CPOs and CTAs would not be required to file Form CPO-PQR...more

Dechert LLP

Financial Services Quarterly Report - Second Quarter 2017: U.S. CFTC Takes Steps to Modernize Rules and Operations and to Reduce...

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Against a backdrop of changing markets, rapidly evolving technology and increased jurisdiction, the U.S. Commodity Futures Trading Commission (CFTC) – the regulatory agency with responsibility for oversight of the U.S....more

Dechert LLP

NFA Adopts Cybersecurity Guidance

Dechert LLP on

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

Dechert LLP

CFTC Proposes to Fix Problematic Oral Communication Recordkeeping Rule

Dechert LLP on

The U.S. Commodity Futures Trading Commission (CFTC) held an open meeting in early November 2014 at which it discussed and proposed, among other agenda items, amendments to rules regarding recordkeeping related to commodity...more

Morgan Lewis

CFTC Proposes Amendments to Recordkeeping Rules

Morgan Lewis on

Proposed changes would provide permanent relief from compliance with certain recordkeeping requirements and narrow the types of records that must be identifiable by transaction. The December 2012 amendments to...more

Morrison & Foerster LLP

Disclosure Requirements and Advertising Rules for CPOs

On August 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) adopted final rule amendments to accept compliance with the disclosure, reporting and recordkeeping rules of the Securities and Exchange Commission...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Amends Certain Record Retention and Document Distribution Requirements for All CPOs and CTAs

On August 13, 2013, the Commodity Futures Trading Commission (CFTC) adopted amendments to certain provisions of Part 4 of the CFTC regulations that are applicable to all commodity pool operators (CPOs) and commodity trading...more

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