Morgan Lewis

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02/10/12 Part I: Update on CFTC Rules 4.5 and 4.13 for Registered Investment Companies and Hedge Funds
Investment advisers operating registered investment companies and private funds that conduct more than a de minimis amount of speculative trading in futures, commodity options, and other commodity interests will no longer be exempt from registering with the CFTC as CPOs.
02/10/12 Part II: Proposal to Harmonize CFTC and SEC Requirements for Registered Investment Companies as Commodity Pools
CFTC requests comments on proposed rules intended to harmonize certain CFTC and SEC disclosure, reporting, and recordkeeping requirements in an effort to mitigate the burden on registered investment companies required to comply with the two separate compliance regimes.
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