October 22, 2019

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CFTC Extends Relief to CTAs With Third-Party Recordkeepers

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has issued exemptive relief to commodity trading advisors (CTAs) from the requirement to keep records under CFTC Regulations 4.7(c)(2) and 4.33 at the CTA’s main business office. As provided in the exemptive letter, a CTA may use a third-party recordkeeper so long as the CTA files a notice of claim with the DSIO containing the representations set forth in the exemptive letter. The notice of claim must be filed at the time the CTA registers with the CFTC and delegates its recordkeeping obligations, or by June 30, 2017, whichever is later.

CFTC Letter No. 17-24 is available here.

In September 2014, DSIO granted similar relief to commodity pool operators, which is available here.

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About this Author

Christian B. Hennion, Finance Attorney, Katten Muchin Law Firm

Christian B. Hennion concentrates his practice in financial services and asset management matters, including counseling fund managers, registered investment advisers and commodity trading advisors on both transactional and regulatory matters. Chris has advised a wide range of US and international managers, from start-ups to large institutions, regarding a variety of matters, including private fund launches and reorganizations, advisory engagements, Investment Advisers Act and Commodity Exchange Act compliance obligations, Securities and Exchange Commission (SEC) and Commodity Futures...

James M. Brady, Katten Muchin Law Firm, Finance Attorney

James Brady concentrates his practice in financial services matters.

While in law school, James was an editor of the Michigan Journal of International Law. He also served as a judicial intern to the Honorable Stephen J. Markman of the Michigan Supreme Court. http://www.kattenlaw.com/James-Brady