The Commodity Futures Trading Commission proposed rule amendments to codify existing staff advisories and no-action letters to authorize commodity pool operators to easier facilitate certain off-shore business, as well as registration relief for CPOs and commodity trading advisers who are or advise family offices or are advisers of business development companies. Separately, the National Futures Association issued guidance to CTAs and CPOs to assist them to more accurately report two financial ratios – the current asset/current liability ratio and total revenue/total expense ratio on quarterly filed NFA Forms PQR and PR. Among other things, NFA noted that both ratios must be calculated using the accrual method of accounting. Additionally, CFTC Chairman J. Christopher Giancarlo issued a white paper recommending a number of cross-border swaps reforms. Mr. Giancarlo recommended that the CFTC use its exemptive authority to authorize comparatively regulated non-US clearinghouses to provide clearing services to US customers indirectly through non-US clearing members and exempt comparably regulated non-US based trading venues from registration with the CFTC as swap execution facilities, among other reforms. (Click here for background on Mr. Giancarlo’s proposals in the article “CFTC Chairman Proposes to Reform Cross-Border Swaps Rules Guidance” in the September 9, 2018 edition of Bridging the Week.)