On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight (“Division”) of the US Commodity Futures Trading Commission (“CFTC”) issued a no-action letter (“Letter 14-126”)1 providing conditional relief from...more
The US Commodity Futures Trading Commission (“CFTC”) has adopted widely anticipated rules regarding the application of its commodity pool operator (“CPO”) regulatory regime to CPOs of registered investment companies...more
Late last week, a senior SEC lawyer encouraged the private equity and hedge fund communities to consider whether certain practices of private fund managers could subject these firms to SEC registration as broker-dealers....more
Over the last few months, an exceptional number of investment management firms have either registered or prepared to register with the Commodity Futures Trading Commission (“CFTC”) as “commodity pool operators” (“CPOs”). Many...more