January 29, 2022

Volume XII, Number 29

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National Futures Association (NFA) to Require Commodity Pool Operators (CPOs) to Identify Registered Investment Companies

The National Futures Association (NFA) has notified its members that it will require each member of the NFA that is registered as a commodity pool operator (CPO) and operates one or more commodity pools that are also registered with the Securities and Exchange Commission as investment companies under the Investment Company Act of 1940 to identify such pools through the NFA’s annual CPO questionnaire. The NFA stated that this information will help the NFA identify the pools that are not required to comply with certain NFA rules and various provisions of Part 4 of the CFTC’s regulations due to their registration as investment companies.

More information on the NFA’s notice can be found here.

©2022 Katten Muchin Rosenman LLPNational Law Review, Volume III, Number 36
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About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm
Partner

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.

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312-902-5372
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