CFTC Staff Permits CPO to Provide Financial Statements for Onshore Feeder Fund Prepared in Accordance with IFRS In Lieu of U.S. GAAP

By: David S. Mitchell, Jessica Forbes, Scott I. Golden, Joanna D. Rosenberg

On March 30, 2018, the Commodity Futures Trading Commission’s (the “CFTC” or “Commission”) Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued an exemptive letter permitting the commodity pool operator (“CPO”) of a U.S. feeder fund that is invested in a Cayman Islands master fund which uses International Financial Reporting Standards (“IFRS”) to provide participants in the U.S. feeder fund, and file with the National Futures Association, financial statements for the U.S. feeder fund prepared in accordance with IFRS, and reconciled to U.S. Generally Accepted Accounting Principles (“U.S. GAAP”) for material differences, in lieu of providing such statements prepared in accordance with U.S. GAAP.

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