"CFTC Announces Significant Amendments to CPO and CTA Registration and Reporting Obligations"

On February 1, 2011, the Commodity Futures Trading Commission (the "CFTC") proposed several amendments to its existing commodity pool operator ("CPO") and commodity trading advisor ("CTA") regulatory structure.  The CFTC solicited comments on the proposed amendments, and on February 9, 2012, the agency issued final rules rescinding the CFTC Rule 4.13(a)(4) exemption from CPO registration; amending the Rule 4.13(a)(3) de minimis exemption from CPO registration; mandating annual notice filing with the National Futures Association for entities seeking exemption under Rule 4.13; amending Rule 4.7 disclosure, reporting and recordkeeping requirements; and adopting Rule 4.27 requiring CPOs and CTAs to periodically report certain information to the CFTC on Forms CPO-PQR and CTA-PR.

This Stroock Special Bulletin summarizes the key amendments to the existing CFTC regulatory framework.