Industry Associations Support Registration Exemption for Foreign CPOs

The Alternative Investment Management Association (AIMA), SIFMA Asset Management Group (AMG), Investment Adviser Association (IAA), Investment Company Institute (ICI) and Managed Funds Association (MFA) (collectively, the "Associations") supported, with suggested modifications, the CFTC's proposals to amend CFTC Rule 3.10(c) (see here and here for previous coverage) to expand the CPO exemption for foreign persons (or, the "Rule 3.10 exemption).

While supporting the CFTC's proposed expansion of the Rule 3.10 exemption, the Associations urged further liberalization of the exemption, particularly as to allowing contributions from U.S. affiliates of a foreign CPO into the foreign pool. The Associations also wanted the CFTC to allow registered or exempt CPOs to rely on the 3.10 exemption while also relying on other exemptions for other activities (e.g., CFTC Rules 4.13(a)(3) and CFTC Rule 4.5).