CFTC Issues No‑Action Relief Easing Registration Requirements For Private Fund Managers

Overview

On December 19, 2025, the Commodity Futures Trading Commission (the "CFTC") issued a no‑action letter (the "No‑Action Letter") that permits many private fund managers registered with the Securities and Exchange Commission (the "SEC") to forgo registering with the CFTC as commodity pool operators ("CPOs") and commodity trading advisors ("CTAs") or to withdraw existing CPO/CTA registrations, subject to certain conditions. The relief responds to a request from the Managed Funds Association (the "MFA") and targets longstanding concerns with duplicative registration for SEC‑registered private fund managers offering pools exclusively to sophisticated investors. Unlike reliance on 4.13(a)(3), this interim relief does not impose a de minimis limit on commodity interest trading for covered pools, although other conditions must be satisfied in order to claim it.