Morgan Lewis Hedge Fund University™ Commodity Pool Regulatory Update

March 06, 2013

Morgan Lewis presented this Hedge Fund UniversityTM webinar series, which discussed recent commodity regulatory developments that are pertinent to managers of commodity pools.

Our panelists addressed U.S. Commodity Futures Trading Commission (CFTC) registration and exemptions, new reporting and recordkeeping requirements, National Futures Association (NFA) Bylaw 1101 and Compliance Rule 2-45, and CFTC and NFA enforcement priorities.

Topics included:

  • Implications of broadening the term "commodity interest" to include swaps and most foreign exchange products
  • CPO registration and available exemptions: the application of the "de minimis test" for swaps and funds of funds
  • Registered CPO/CTA regulatory requirements and available relief under CFTC Rule 4.7
  • Forms CPO-PQR and CTA-PR
  • Loans to CPOs and affiliated entities: NFA Compliance Rule 2-45
  • Doing business with non-NFA members

View the presentation >