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The CFTC set a comment deadline of December 11, 2023 for a proposal that would (i) raise the amount of money required to invest in funds under certain CFTC Rule exemptions with respect to offerings to "qualified eligible persons" and (ii) increase the disclosure requirements applicable to such funds.

The CFTC proposed raising the amount of money required to invest in funds under CFTC Rule 4.7 ("Exemption from certain part 4 requirements for commodity pool operators with respect to offerings to qualified eligible persons") and increasing the disclosure requirements applicable to such funds.

The CFTC's proposed amendments to the trade option exemption for end users were published in the Federal Register. The trade option exemption pertains to reporting requirements for trade option counterparties that are not swap dealers or major swap participants, as well as to recordkeeping requirements for trade option counterparties that are not swap dealers or major swap participants. The CFTC proposed the elimination of the Form TO annual notice reporting requirement for otherwise unreported trade options in CFTC Rule 32.3(b). Under the proposal, a counterparty that is not a swap dealer (