CFTC Proposes Amendments to Commodity Pool Operator Periodic and Annual Reporting Requirements

By: David S. Mitchell, Mark Molle

The Commodity Futures Trading Commission (the “CFTC”) has proposed for public comment various amendments to its rules governing the periodic and annual reporting requirements applicable to commodity pool operators (“CPOs,” each a “CPO”), including both registered CPOs and CPOs who are exempt from registration pursuant to applicable CFTC rules.   The proposed amendments are designed to clarify ambiguity in the current rules, simplify the process by which CPOs of funds-of-funds may seek extensions from the annual reporting deadline, streamline the filing procedures and reporting requirements for liquidating pools and codify current industry practice with respect to reporting by CPOs.  Comments must be submitted on or before March 26, 2009.

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