Tag Archives: CTA

Attention Mutual Funds–Potential Relief for CPO and CTA Regulation in the 2014 CFTC Reauthorization Act

As the second part of our ongoing series on the 2014 CFTC Reauthorization Act, we wanted to highlight what could become important relief for mutual funds and their investment advisers with respect to registration as commodity pool operators or commodity trading advisers.… Continue Reading

CFTC Provides Time Limited Relief to Oral Recordkeeping Requirements for CTAs — UPDATE to: One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements

By Andrew Cross and Tom Watterson In our November 1, post “One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements” we sought to raise awareness regarding increased recordkeeping requirements for SEF members under CFTC Rule 1.35(a). CFTC Rule 1.35(a) generally requires “members” of a SEF (or an exchange) to maintain oral records (i.e., … Continue Reading

Attention Compliance Officers: SEC, CFTC and FINRA Issue Best Practice Statement for Business Continuity and Disaster Recovery Planning

On August 16th, the SEC, CFTC and FINRA issued a statement regarding best practices with respect to business continuity planning.  The statement resulted from a joint review of the impact that Hurricane Sandy had on the business continuity and disaster recovery planning programs of several large firms affected by the October 2012 event.  Particular attention … Continue Reading

A Focus on Offshore and Non-U.S. Fund Operators & Advisers: Regulatory Exemptions from Commodity Pool Operator (CPO) & Commodity Trading Advisor (CTA) Registration – CFTC Rule 3.10

Introduction In light of the implementation of Title VII of the Dodd-Frank Act by the U.S. Commodity Futures Trading Commission ("CFTC") and consequential regulatory overhaul of the U.S. derivatives markets, many offshore investment funds and their advisers have expressed an interest in available exemptions from the registration requirements that apply to a commodity pool operator … Continue Reading

Attention Private Hedge Funds, Registered Investment Companies and Registered Investment Advisers – The CFTC and SEC Have Proposed Rules That Will Affect You

Links to Relevant Documents; Overview of Relevance A joint SEC/CFTC Rule Proposal for Reporting on Form PF by Investment Advisers,  Commodity Trading Advisors, and Commodity Pool Operators to Private Funds available here   A Press Release and a Fact Sheet for new CFTC rule proposals that will effect mutual funds (registered investment companies), hedge funds, registered investment advisers, commodity … Continue Reading