CFTC Proposes Part 4 Rule Amendments to Codify Certain CPO and CTA Relief
By: William J. Breslin, Darren A. Littlejohn, David S. Mitchell, Scott I. Golden
On October 9, 2018, as part of its Project KISS initiative to streamline and simplify its rules, the U.S. Commodity Futures Trading Commission (the “Commission” or “CFTC”) issued a notice of proposed rulemaking (the “CFTC Rule Proposal”) to amend its Part 4 Rules, which govern the operations and activities of commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”). Among other things, these amendments would add certain exemptions from registration based upon relief provided under existing CFTC staff letters and advisories such as CFTC Staff Advisory 18-96 (“Advisory 18-96”), and codify other existing regulatory relief, including that provided by CFTC Staff Letter 14-116 (the “JOBS Act Relief Letter”).
