News & Analysis as of August 17, 2025

Investment Companies

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A Commodity Pool is an investment structure or enterprise where funds from a number of participants are combined into a single entity for the purpose of trading futures contracts, options on contracts, retail... more +

Customer Segregation: Keep It Separate

The deadline for re-affirming CPO exemptions/exclusions is approaching

Eversheds Sutherland (US) LLP on 2/14/2025

Under Commodity Futures Trading Commission (CFTC) regulations, persons who have claimed an exemption or exception from commodity pool operator (CPO) or commodity trading advisor (CTA) status pursuant to Part 4 of the CFTC’s...more

New CFTC Rules Taking Effect: Investment Advisers to Registered Investment Companies (RICs) Must Claim the Rule 4.5 CPO Exclusion...

Kilpatrick on 12/1/2020

On December 10, 2019, the Commodity and Futures Trading Commission (“CFTC”) published amendments to the rules governing Commodity Pool Operators (“CPOs”) and Commodity Trading Advisers (“CTAs”) (the “New Rules"). Among other...more

CFTC and NFA Year End Regulatory Updates

Akin Gump Strauss Hauer & Feld LLP on 12/27/2019

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

Treasury Report Addresses Regulatory Approaches Affecting Investment Companies and Their Advisers

Troutman Pepper Locke on 10/31/2017

As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more

Cybersecurity Update: National Futures Association Proposes Cybersecurity Guidance Setting Forth General Requirements for Member...

K&L Gates LLP on 9/10/2015

The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more

CFTC Adopts Final Harmonization Rules for Registered Investment Company Advisers Required to Register as CPOs Under Regulation...

Katten Muchin Rosenman LLP on 8/21/2013

On August 13, 2013, the Commodity Futures Trading Commission issued its final rules (“Final Rules”) applicable to registered investment companies now required to dually register as commodity pool operators (“Dually-Registered...more

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