Clifford Chance

CFTC Significantly Limits the Exemption from Commodity Pool Operator Registration for Registered Investment Advisers and Rescinds the Registration Exemptions for Private Fund Managers and Trading Advisers

21 February 2012

On February 9, 2012, the Commodity Futures Trading Commission (the "CFTC") issued a final rule (the "Final Rule") to remove the exemptions that permitted many registered investment advisers and private investment fund managers to avoid the need to register as commodity pool operators ("CPOs") or commodity trading advisors ("CTAs") in the United States. The Final Rule imposes extensive reporting requirements on certain registered CPOs and CTAs.

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