We would like to ensure that you are still receiving content that you find useful – please confirm that you would like to continue to receive ILO newsletters.
24 September 2014
On September 3 2014 the US Commodity Futures Trading Commission's (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter for commodity pool operators (CPOs) of certain commodity pools that are non-registered investment companies ('parent pools') and use wholly owned trading subsidiaries to trade commodity interests. In cases where CPOs do not provide a separate annual report(1) or a separate Form CPO-PQR report for a parent pool's trading subsidiary to the National Futures Association,(2) the DSIO recommends that the CFTC not take enforcement action, as long as:
For further information on this topic please contact Donna M Parisi, Geoffrey B Goldman or Azam H Aziz at Shearman & Sterling LLP by telephone (+1 212 848 4000), fax (+1 212 848 7179) or email (firstname.lastname@example.org, email@example.com or firstname.lastname@example.org).The Shearman & Sterling website can be accessed at www.shearman.com.
The materials contained on this website are for general information purposes only and are subject to the disclaimer.
ILO is a premium online legal update service for major companies and law firms worldwide. In-house corporate counsel and other users of legal services, as well as law firm partners, qualify for a free subscription.