The CFTC has just issued its long-awaited release on the harmonization of the CFTC’s regulations for commodity pool operators (CPOs) to registered investment companies, with the SEC’s regulations.
On April 24, 2012, the CFTC amended its CPO exclusion for operators of registered funds, Regulation 4.5. The CFTC imposed new de minimis trading limitations and a marketing test. Operators of registered funds that could not comply with amended Regulation 4.5 were required to register as CPOs by January 1, 2013. And, advisers to those funds were required to register as commodity trading advisors (CTAs) unless another exemption was available.
However, the CFTC suspended compliance with the CFTC’s disclosure, reporting and recordkeeping regulations for these CPOs and CTAs until it issued its harmonization release. This program was designed to give CPOs of registered funds and CTAs a head start on how to comply with new requirements.
The topics this program addresses include:
The program features speakers, who have been actively involved in both compliance with the new regulatory registration scheme and the rule-making process on behalf of both registered and private fund operators.