The CFTC's newly adopted revisions will have a significant impact on private fund managers currently exempt from CPO and CTA registration. Paul Architzel, Jeannette Boot and Matthew Chambers discussed and answered questions on the revisions to the rules relating to registration by collective investment vehicles, including:
- revisions to the requirements for the 4.5 exemption for registered investment companies;
- revisions to the de minimis exemption for commodity pool registration; and
- withdrawal of the exemption under rule 4.13(a)(4)) for "qualified eligible persons."
In addition, they examined new reporting requirements for commodity pool operators as well as proposed rules to harmonize compliance with both investment company and commodity pool operator requirements.
WilmerHale's featured speakers included Partners Paul Architzel, Jeanette Boot and Matthew Chambers.
