Seward & Kissel Issues Memorandum Regarding Reliance on the 4.13(a)(3) Exemption from Registration as a Commodity Pool Operator

May 2, 2012

Effective April 25, 2012, the CFTC adopted amendments to Part 4 of its regulations, rescinding the exemption from commodity pool operator ("CPO") registration in CFTC Regulation 4.13(a)(4).  This memorandum describes the Rule 4.13(a)(3) exemption and common issues that arise for managers as they seek to determine whether they are able to rely upon the exemption.  Additional guidance on the registration process and the exemptions that may be available to the private investment funds advised by a registered CPO will be provided in a future memorandum.
Click here to access the memorandum.


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Investment Advisers, Investment Companies, Regulatory