CFTC Issues Far-Reaching Proposal to Amend Registration Requirements for CPOs and CTAs
October 22, 2026
Hedge Fund Law Report
Partner Raymond Ramirez discusses the CFTC's proposed Regulation 4.13(a)(4) that could ease registration requirements for SEC-registered investment advisers that operate commodity pools for qualified eligible persons.
He discusses the proposal’s history and the considerations that led to this recent development, including signaling a shift toward reducing duplicative regulatory requirements.
"When the CFTC rescinded its exemption for private funds in 2012, market participants had to go out and find other exemptions. So the CFTC is essentially bringing the rescinded 2012 exemption back, although with some differences," Ray said.