Regulatory Compliance Association Reviews

Commodity Pool Operator and Commodity Trading Advisor Registration & Regulation for Investment Fund Managers™

Practice Edge 02

Commodity Pool Operator and Commodity Trading Advisor Registration & Regulation for Investment Fund Managers™

Date: December 11, 2014
General Session: 12 Noon to 1:30 PM
Location: Webcast (Free)

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An increasing number of SEC-registered investment advisers are now managing and/or advising private funds that invest in “commodity interests,” (defined in the Commodity Exchange Act) and are therefore subject to regulation by the Commodity Futures Trading Commission (“CFTC”). This class session will review the determination of whether or when an investment adviser is required to register as a commodity pool operator and/or a commodity trading advisor. The session will then outline the steps involved in registering as a commodity pool operator or commodity trading advisor and becoming a member of the National Futures Association (“NFA”), and provide a broad overview of the post-registration compliance requirements under CFTC and NFA rules and regulations, including some specific differences from investment adviser compliance obligations.

 Students will master the following at the conclusion of this session:

• define a “commodity interest;”
• differentiate between a commodity pool operator and a commodity trading advisor;
• determine whether commodity pool operator and/or a commodity trading advisor registration is required;
• list the commonly relied upon exemptions from commodity pool operator and commodity trading advisor registration;
• identify the steps required to register as a commodity pool operator and rely on CFTC Rule 4.7;
• determine the investment adviser’s “associated persons” and “principals;”
• develop relevant compliance procedures to supplement the firm’s existing compliance program; and
• identify regulatory “trouble spots” focused on by the CFTC and/or NFA.

Session Chairman:
Walter Zebrowski, JD, CPA, Principal, Hedgemony Partners
Chairman, Regulatory Compliance Association

Senior Fellow from Practice:
Matt Eisenberg, JD, Partner, Finn Dixon & Herling

Guest Lecturers:

Michael Sheehy, Senior Vice President & Chief Compliance Officer, CoreCommodiity Management
Justin Shigemi, JD, Senior Associate, Finn Dixon & Herling
Richard Kilbride, JD, Counsel, Finn Dixon & Herling
Tracey Hunt, CPA, CFE, Associate Director – Compliance, NFA
Patricia Cushing, CPA, Director – Compliance, NFA

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