Posts tagged as:

Commodity Pool Operator

CFTC Provides Annual Guidance to CPOs

January 28, 2010

Annual Report Guidance for Commodity Pool Operators
In a recent release, which we have reprinted in full below, the CFTC reminds CPOs of their annual reporting requirements under Regulation 4.22.  The release includes a link to the 2010 CPO Annual Guidance Letter.  In general the letter provides another reminder to CPOs to file their annual reports [...]

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CPO Reporting Requirements | Commodity Pool Operator Compliance

November 20, 2009

CFTC Regulation 4.22 Overview

CFTC registered commodity pool operators have a number of regulatory and compliance issues to be aware of.  In addition to a having a compliance program which addresses the business and regulatory issues applicable to the manager, one of the more important compliance requirements is found in CFTC Regulation 4.22 which provides the [...]

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CTA and CPO Registration and Compliance Guide

October 15, 2009

Practical guidance for CTA and CPO firms
Commodity Trading Advisors (CTAs) and Commodity Pool Operators (CPOs) have been contacting me with greater regularity and we have decided to provide those firms with more detailed information on their registration and compliance requirements. Over the course of the next few weeks we will be continually updating [...]

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NFA Rule Compliance Rule 2-45 Approved

September 26, 2009

CPOs Prohibited From Taking Loans From Commodity Hedge Funds
The CFTC just recently approved a new NFA compliance rule which prohibits commodity pool operators (CPOs) from taking loans from the commodity pools which they manage. Additionally, if a CPO currently has some sort of a loan arrangement with their fund, such CPO will have until [...]

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Commodity Pool Operators Scrambling After Surprise CFTC Decision

August 20, 2009

CFTC Withdraws Two No-Action Letters
In a surprise move the CFTC has withdrawn two no-action letters which is had just recently issued.  Under the new Chairman Gary Gensler, the CFTC has made an about face on this issue with regard to two commodity pool operators who were relying on the no-action letters issued in 2006.  Under [...]

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Series 3 Exam | Commodities & Futures Exam Topics

July 22, 2009

Hedge Fund Managers and the Series 3 Exam
Those managers who engage in commodities and futures trading (and who don’t qualify for an exemptions) will need to register as commodity pool operators with the CFTC and become members of the NFA.  In order to do this all owners and “associated persons” of the manager/CPO will need [...]

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NFA Cracks Down on CPO Fraud with New Compliance Rule

May 29, 2009

Proposes Amendments to Compliance Rule 2-45
The National Futures Association (NFA) proposed new amendments to Compliance Rule 2-45 regarding prohibition of loans by pools to commodity pool operators and related parties.  The amendment states that no Member CPO may permit a commodity pool to use any means to make a direct or indirect loan or advance [...]

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CPO Exemption for Fund of Hedge Funds

May 15, 2009

As we have discussed previously, if a hedge fund manager invests fund assets in commodity interests (including futures), then the manager will generally need to be registered as a commodity pool operator (CPO) with the Commodity Futures Trading Commission (CFTC).  The registration requirement also applies to fund of fund (FOF) managers who allocate assets to [...]

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CPOs and CTAs Now Submit Disclosure Documents Electronically

April 7, 2009

NFAs Electronic Filing System Went Live Yesterday
The NFAs new electronic filing system for CPO and CTA disclosure documents went live yesterday.  All NFA members are required to use the electronic system for filing their disclosure documents.   While I have not yet used the new system, it is expected to be a big improvement over the [...]

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Two Separate CPOs Subject to NFA Action

February 10, 2009

In two separate actions the NFA has effectively shut down two separate Commodity Pool Operators who were operating in the Northeast.  The press releases are reprinted below.
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For Immediate Release
NFA takes emergency enforcement action against New York commodity pool operator
February 9, Chicago - National Futures Association (NFA) announced today, that it has taken an emergency enforcement [...]

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