The Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) will hold a joint public event on Thursday, January 29, 2026 (rescheduled from Tuesday, January 27), at the CFTC Headquarters in Washington, D.C., to discuss harmonization of the regulatory approach taken by the agencies and U.S. leadership in the crypto era. The
CFTC Staff Partially Reinstate CPO Exemption for RIAs
Posted in CFTC
On December 19, the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”) issued no-action relief from commodity pool operator registration for SEC-registered investment advisers to certain private funds. This relief effectively reinstates the registration exemption previously provided by Rule 4.13(a)(4) for managers to private funds offered solely to qualified…
Risk Transfer Market Receives CPO Registration Relief from CFTC
By Matthew Bisanz, Stuart M. Litwin, Anna T. Pinedo, Julie A. Gillespie, Marla Matusic, Sagi Tamir & Jeffrey P. Taft on
Posted in CFTC, Structured Finance
On November 21, 2025, the Structured Finance Association, on behalf of the risk transfer market, received no-action relief on the issue of registration as a commodity pool operator (“CPO”) from the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”). This long-awaited relief provides greater certainty that participants in certain…
NFA Streamlines Process for Virtual Currency Activities by CFTC Registrants
By Matthew Bisanz & Kelly Truesdale on
Posted in CFTC, Digital Assets
On October 17, 2025, the National Futures Association (“NFA”) announced a proposal to repeal requirements that firms that are registered with the Commodity Futures Trading Commission (“CFTC”) must make certain disclosures to customers regarding virtual currency activities.
The repeal of the disclosure requirements will take effect 10 days after the CFTC receives NFA’s proposal, unless…
SEC and CFTC Extend Compliance Deadline for Form PF Amendments
By Anna T. Pinedo on
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have extended the compliance deadline for the amendments to Form PF, moving it from March 12, 2025 to June 12, 2025.
The SEC adopted amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, including those…
CPO and CTA Rule Proposals
By Anna T. Pinedo on
Posted in CFTC, Dodd-Frank
Earlier this month, the Commodity Futures Trading Commission proposed rules that would codify certain relief provided to commodity pool operators and commodity trading advisors in the post Dodd-Frank Act years. The relaxation of the prohibition against general solicitation in Rule 144A offerings and certain Rule 506 offerings led to ambiguity regarding CFTC Rules 4.7(b) and…