How we can help commodity pool operators

October 2012


In February 2012, the CFTC approved rules that will require some private fund managers and investment companies to register with the CFTC as commodity pool operators (“CPOs”). The new rules:

  • Rescind an exemption from the CPO registration requirement that many advisers to private funds relied on (the “hedge fund exemption”); and
  • Reinstate a rule that says that registered investment companies – despite being registered with the SEC – will have to also register with the CFTC if they trade commodity interests above a certain threshold or if they market their funds as providing exposure to commodity interests.

Contact us

Dan Ryan
US Banking and Capital Markets Leader
Tel: +1 (646) 471 8488

Alison Gilmore
US Asset and Wealth Management Marketing Leader
Tel: +1 (646) 471 0588