CFTC’s Division of Swap Dealer and Intermediary Oversight Responds to Questions Regarding Recent Amendments to Compliance Obligations for Commodity Pool Operators and Commodity Trading Advisors

The CFTC Division of Swap Dealer and Intermediary Oversight issued a set of responses to frequently asked questions ("FAQs") addressing compliance obligations for CPOs and CTAs and other issues related to commodity pools. The FAQs address a variety of issues/concerns related to the compliance obligations for CTAs and CPOs raised by market participants, including compliance dates, the regulatory status of wholly owned subsidiaries of commodity pools, trading limits for purposes of complying with CFTC Rule 4.13(a)(3), AP registration requirements for persons registered under the Investment Company Act, and the process for transitioning from an exemption from registration under CFTC Rule 4.13(a)(4) to either registering or claiming another exemption. The FAQs also provide limited guidance as to persons/entities who qualify as CPOs and investment vehicles that qualify as commodity pools.

Cross-Reference(s): CFTC Reg. 4.13(a)(4).

View release in full here; Response to FAQ (links externally to CFTC website).