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As a result of changes made by the 2010 Dodd-Frank Act, sponsors, managers and advisers to private funds may now be required to register with the U.S. Commodity Futures Trading Commission as commodity pool operators ("CPOs") and/or commodity trading advisers ("CTAs").  The CFTC has already repealed two of the most relied-upon exemptions from CPO and CTA registration, with effect from April 2012.  Soon, the CFTC's regulatory authority over private funds and their managers will reach even further, once action is taken to include swaps within the category of "regulated commodity interests", because exposure to more than a de minimis amount of such interests may trigger CPO and CTA registration requirements.  Private fund sponsors, managers and advisers should take steps now to reassess their obligations under the new CFTC registration regime. 

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