On February 9, 2012, the Commodity Futures Trading Commission adopted final rule amendments that rescind a commonly-used exemption from registration as a commodity pool operator (“CPO”) and add new limitations to an exclusion from the definition of CPO upon which registered investment companies have commonly relied. The CFTC also adopted additional reporting and disclosure requirements for CPOs and commodity trading advisers and proposed new rule amendments that seek to harmonize certain of its requirements with those applicable to registered investment companies under SEC regulations.
Our Alert highlights the key components of these final and proposed rule amendments and discusses certain practical consequences that they will have for investment advisers and registered investment companies. The Alert also provides a brief timeline of when the final rule amendments will be implemented.
To read the Alert, please click here.
This article was originally published by Bingham McCutchen LLP.