CFTC Adopts Final Rules Revising CPO and CTA Registration and Reporting Requirements: Significant Impacts for Mutual Funds and Private Investment Funds
February 16, 2012
BY THE INVESTMENT MANAGEMENT PRACTICE
The CFTC recently adopted final amendments to the compliance obligations of commodity pool operators and commodity trading advisors that, among others, would rescind or modify several CFTC registration exemptions and exclusions commonly relied upon by registered investment companies (e.g., mutual funds) and private investment fund sponsors and establish a periodic reporting regime for commodity pool operators and commodity trading advisors. At the same time, the CFTC separately proposed certain changes to the disclosure and reporting obligations of registered investment companies required to register as commodity pool operators in order to harmonize the requirements of CFTC disclosure obligations with those of the SEC.