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Reminder: CPO and CTA Annual Affirmation Requirement

Client memorandum | February 10, 2021

The Commodity Futures Trading Commission (“CFTC”) requires any person that claims an exemption from commodity pool operator (“CPO”) registration under CFTC Rule 4.13, except for any person claiming the exemption for family offices under Rule 4.13(a)(6), 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, 2021.

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