Financial Services & Products Advisory

CFTC Extends Compliance Date for Amended Rules 4.5 and 4.13(a)(4) Regarding CPO/CTA Registration

On July 13, 2012, the Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued a letter (the “No Action Letter”) to the Managed Funds Association, the Investment Company Institute, and other industry associations that extends relief from compliance with the changes to Regulations 4.13(a)(4) and 4.5 until the end of the year for commodity pool operators (CPOs) and commodity trading advisors (CTAs) of pools launched after July 13, 2012. This advisory discusses how CPOs and CTAs for pools launched after July 13, 2012, may rely on the rescinded 4.13(a)(4) exemption and the amended 4.5 exclusion through the end of the year if they comply with certain criteria.

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