On May 12, the Commodity Futures Trading Commission staff issued guidance for so-called “CPO delegation” arrangements, which are situations where an individual or entity that could otherwise be obligated to register with the CFTC as a commodity pool operator (a “CPO”) seeks to delegate its commodity pool operator authority to another person.

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Yesterday, the Commodity Futures Trading Commission (the “CFTC”) announced several important updates related to swap execution facilities (“SEFs”):

1. CFTC Website Location for MAT Swaps. The CFTC announced that it has published a centralized list of swaps subject to the swap execution mandate, or otherwise known as “MAT trades.” This dedicated webpage is intended

The Commodity Futures Trading Commission (the “CFTC”) announced its first two “made available for trade” determinations (each, a “MAT Determination”), which mandate that fund managers trade certain benchmark interest rate swaps on behalf of their funds and managed accounts through a swap execution facility (a “SEF”) or a designated contract market (a “DCM”). Once a

On Dec. 21, 2013, the U.S. Commodity Futures Trading Commission issued broadly applicable no-action relief deferring (through May 1, 2014) the effectiveness of recordkeeping requirements that would have required fund managers registered as commodity trading advisors who hold swap execution facility memberships to preserve oral communications (including telephone calls) relating to any trading of commodity

As regulated entities, registered commodity pool operators have obligations to maintain and have ready access to a prescribed set of books and records. On August 13, in recognition of widespread market practice, the CFTC adopted regulations permitting CPOs to maintain certain books and records with a third party. Eligible third party recordkeepers under the new

Approximately six months ago (on Dec. 21, 2012), the Commodity Futures Trading Commission staff provided temporary no-action relief allowing certain equity total return swaps on foreign securities — which have been termed “compo equity swaps” or “compo equity total return swaps” — to be treated as “securities-based swaps” (which are regulated by the Securities and

Investment funds (or investment managers on their behalf) may now adhere to the ISDA March 2013 DF Protocol Agreement (“Protocol 2.0”). Protocol 2.0, as with the ISDA August 2012 DF Protocol (the “August Protocol”), is an efficient means for swap dealers to comply with certain new Commodity Futures Trading Commission (“CFTC”) rules applicable to bilaterally

Given the large number of regulatory developments coming from the Commodity Futures Trading Commission, the National Futures Association and other regulatory agencies, we have compiled a short list of important recent and upcoming deadlines facing commodity pool operators and investment advisers. Along with each deadline, the list provides a concise summary of certain actions that

On April 30, 2013, the Commodity Futures Trading Commission staff issued a letter granting temporary relief to swap dealers from compliance with certain “external business conduct standards” related to foreign exchange and swap prime brokerage arrangements. This relief is not expected to impose any new obligations on investment advisers. However, it forestalls a potential market

The Commodity Futures Trading Commission (“CFTC”)’s April 10, 2013 deadline for investment funds that are U.S. Persons to comply with swap data reporting and recordkeeping rules is fast approaching. Investment funds must also obtain a CFTC Interim Compliant Identifier (“CICI”) by this deadline date.

If an investment fund is trading with a CFTC-registered swap