On July 13th, the CFTC's Division of Swap Dealer and Intermediary Oversight issued time-limited no-action relief for commodity pool operators ("CPOs") and commodity trading advisors ("CTAs") who have been exempt or excluded from registration but, because of recent amendments to Commission Regulations 4.13 and 4.5, now need to register and satisfy compliance obligations. The Division has recommended that the CFTC not take enforcement actions against CPOs or CTAs for failure to register until December 31, 2012 if they file a notice with the Division, among other things. CFTC Press Release.
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Division of Swap Dealer and Intermediary Oversight issues time-limited no-action relief to certain CPOs and CTAs to meet registration and compliance obligations
- Winston & Strawn LLP
- July 23 2012
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