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ARTICLE · 14 JUNE 2019

Cadwalader Updates Disclosure Chapter Of CEA Guide

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The Cabinet updated the "Disclosure, Reporting, and Recordkeeping Requirements" chapter of the Cadwalader Guide to Commodities Regulation.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The Cabinet updated the " Disclosure, Reporting, and Recordkeeping Requirements" chapter of the Cadwalader Guide to Commodities Regulation. The Guide is applicable to CPOs and CTAs that provide services to public and private commodity pools, including SEC-registered investment companies that are treated as commodity pools under the Commodity Exchange Act.

In addition to providing current materials since this chapter was last revised, the chapter covers:

  • amendments adopted by the CFTC in 2017 to facilitate the modernization of storage of electronic records that take advantage of recent enhancements in information technology; and
  • new requirements by NFA that require CPOs to design and implement "internal controls" to ensure that the books and records of their commodity pools are current and accurate.

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