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ARTICLE · 19 JUNE 2019

CFTC Grants CPO Relief From Registration Requirements

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The CFTC Division of Swap Dealer and Intermediary Oversight granted no-action relief to a CPO from registration requirements.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The CFTC Division of Swap Dealer and Intermediary Oversight granted no-action relief to a CPO from registration requirements.

The CPO acted as a general partner of a "Fund Complex" that consists of seven private investment funds. According to the CFTC Letter, "the Funds are generally required by their organizational and offering documents to invest in parallel and will pursue the same investment strategy and generally invest side-by-side in the same positions as each other." As part of the Fund Complex arrangement, the general partner operates a special purpose entity that has no direct investors other than the Funds, each of which invests less than 3% of its committed capital into the entity.

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