Tag Archives: mutual funds

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

Reminder for Investment Managers of RICs of Form CPO-PQR Filing Requirements

By Tom Watterson In amending the CPO/CTA registration rules in February of 2012, the CFTC amended CFTC Rule 4.27 to require registered CTAs and CPOs to report information and data to the CFTC on Forms CTA-PR and CPO-PQR. In addition NFA rule 2-46 requires those with reporting obligations under CFTC Rule 4.27 to report Form NFA-PQR. … Continue Reading

Mutual Fund Corner: On August 31st, SEC to Consider Whether to Issue a Concept Release On The Use of Derivatives By Mutual Funds

In an August 24th Sunshine Act Notice (available here), the SEC announced that it hold a pubic meeting on August 31st to consider, among other things,…drumroll please... whether to issue a concept release and request public comment on a wide range of issues under the Investment Company Act raised by the use of derivatives by … Continue Reading

Mutual Fund Corner: SEC Issues CME a Rule 17f-6 Letter for OTC Cleared Interest Rate Swaps

On March 24th, the SEC’s Division of Investment Management issued a no-action letter under Rule 17f-6 to the CME that will allow mutual funds to post collateral in respect of OTC centrally cleared interest rate swaps directly with their futures commission merchants. The letter provides temporary relief until July 16th, which is the date on which … Continue Reading

SEC No-Action Letter Update: Mutual Funds Can Post Margin on Centrally Cleared Interest Rate Swaps

In a March 16th No-Action Letter, LCH.Clearnet Limited ("LCH") received a no-action letter from the SEC’s Division of Investment Management ("IM Division") that, in effect, permits a mutual fund to "place and maintain assets in the custody of" LCH or a clearing member of LCH (the "Clearing Member") for purposes of meeting margin requirements for interest … Continue Reading

Op Ed: January 26th – A Microcosm of U.S. Derivatives Regulatory Reform

Two different events occurred on January 26th that we believe represent a microcosm of the entire U.S. derivatives regulatory reform process to date. EVENT #1: THE JANUARY 26TH PROPOSAL The 11th open meeting on Dodd-Frank derivatives market regulatory reforms was scheduled to be held by the CFTC. While the agenda included issues related to the … 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