News & Analysis as of August 2, 2025

Commodity Pool › Regulatory Requirements

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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

CFTC Proposes Amendments to CPO, CTA Regulations

WilmerHale on 10/11/2023

The Commodity Futures Trading Commission (CFTC or Commission) recently proposed amendments to CFTC Regulation 4.7 (the Proposed Rule) that would impact long-standing exemptions from certain compliance requirements for...more

National Futures Association Proposes New Reporting Requirements for Commodity Pool Operators

Morgan Lewis on 3/10/2021

The National Futures Association (NFA) has proposed a new rule that would require registered commodity pool operators (CPOs) that are members of the NFA (CPO Members) to report to the NFA by 5:00 pm Central Time the next...more

CFTC Proposes Relief for Non-US Commodity Pool Operators

Morgan Lewis on 6/9/2020

The US Commodity Futures Trading Commission has proposed amendments to CFTC Regulation 3.10(c)(3) to allow non-US commodity pool operators to claim an exemption from registration with respect to their offshore commodity pools...more

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

Cadwalader, Wickersham & Taft LLP on 1/17/2020

The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

CPO and CTA Rule Proposals

Mayer Brown Free Writings + Perspectives on 10/29/2018

Earlier this month, the Commodity Futures Trading Commission proposed rules that would codify certain relief provided to commodity pool operators and commodity trading advisors in the post Dodd-Frank Act years....more

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