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CFTC Proposes Part 4 Rule Amendments to Codify Certain CPO and CTA Relief

USA - October 12 2018 On October 9, 2018, as part of its Project KISS initiative to streamline and simplify its rules, the U.S. Commodity Futures Trading Commission (the…

William J. Breslin, Darren A. Littlejohn, David S. Mitchell.

CFTC Proposes to Amend Annual Report Requirements for Commodity Pool Operators

USA - August 15 2016 The Commodity Futures Trading Commission (the "Commission" or "CFTC") recently published certain proposed amendments to its rules governing the…

William J. Breslin, Victoria T. Mazgalev, Robert M. McLaughlin, David S. Mitchell.

Reminder: CPO and CTA Annual Affirmation Requirement

USA - January 31 2019 The Commodity Futures Trading Commission ("CFTC") requires any person that claims an exemption from commodity pool operator ("CPO") registration…

William J. Breslin, David S. Mitchell.

NFA Issues New Reporting Requirements for Member CPOs and CTAs That Trade Virtual Currency Products

USA - January 26 2018 On December 14, 2017, the National Futures Association (“NFA”) issued a Notice to Members (the “Notice”) requiring each registered commodity pool…

William J. Breslin, Darren A. Littlejohn, Victoria T. Mazgalev, Robert M. McLaughlin, David S. Mitchell, Matthew S. Smith.

NFA Amends Guidance on Information Systems Security Programs and Proposes New Guidance on Internal Controls Systems for CPOs

USA - January 10 2019 By letter dated December 4, 2018, the National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) proposed…

William J. Breslin, David S. Mitchell.