Tag Archives: CFTC


CFTC Grants Self-Executing No-Action Relief for CPOs

October 21, 2014 Dear Friends, The CFTC has further streamlined its Commodity Pool Operator (“CPO”) delegation process, granting self-executing, no-action relief to qualifying CPOs that delegate their CPO functions to a registered CPO. In May 2014, the CFTC required CPOs that delegate certain responsibilities to a registered CPO (e.g. GPs of limited partnerships that delegate CPO authority to a registered CPO) to submit […]

CFTC Issues JOBS Act Relief

September 10, 2014  Dear Friends, The CFTC issued an exemptive letter harmonizing its rules with the SEC’s JOBS Act amendments, lifting the ban on general solicitation for certain CPOs, in connection with private securities offerings.  Previously, the CFTC’s marketing restrictions on private offerings prevented CPOs from engaging in general solicitations. The relief granted by the CFTC is not self-executing – CPOs […]

CFTC Guidance on CPO Delegation Process

Dear Friends, On May 12, 2014, the CFTC announced a streamlined approach for considering requests for no-action relief with respect to CPOs who delegate certain activities to a registered CPO (e.g. GPs of limited partnerships who delegate CPO authority to a registered investment manager). Each delegating CPO must submit a letter certifying it meets certain criteria outlined in the release. […]