Reminder: CPO and CTA Annual Affirmation Requirement

By: William J. Breslin, David S. Mitchell, Scott I. Golden

The Commodity Futures Trading Commission (“CFTC”) requires any person that claims an exemption from commodity pool operator (“CPO”) registration under CFTC Rule 4.13, including most notably Rule 4.13(a)(3), an exclusion from the CPO definition under Rule 4.5, or an exemption from commodity trading advisor (“CTA”) registration under Rule 4.14(a)(8) to annually affirm the applicable notice of exemption or exclusion within 60 days of the calendar year end.  Affirmations for the current cycle are due no later than March 1, 2018.

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