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ARTICLE · 25 OCTOBER 2023

CFTC Proposes New Disclosure Requirements For Certain Commodity Pool Operators And Trading Advisors

Ropes & Gray LLP
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The U.S. Commodity Futures Trading Commission ("CFTC") recently proposed an amendment to Rule 4.7 (the "Proposal") that would (i) introduce new minimum disclosure requirements...

United StatesFinance and Banking
Jeremy A. Liabo
Jeremy A. Liabo
Laura E. Appelt
Laura E. Appelt
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The U.S. Commodity Futures Trading Commission ("CFTC") recently proposed an amendment to Rule 4.7 (the "Proposal") that would (i) introduce new minimum disclosure requirements for commodity pool operators ("CPOs") and commodity trading advisors ("CTAs") who operate pools and trading programs pursuant to CFTC Rule 4.7 ("Rule 4.7 CPOs and CTAs"), (ii) increase the monetary thresholds to qualify as a Qualified Eligible Person ("QEP"); and (iii) codify routinely issued exemptive relief allowing CPOs of funds-of-funds operated under Rule 4.7 to choose to distribute monthly account statements within 45 days of month-end.1

Background

The CFTC adopted Rule 4.7 over 30 years ago to provide an exemption from certain disclosure, recordkeeping and filing requirements to CPOs and CTAs who operate privately offered pools and direct trading programs that are available exclusively to financially sophisticated investors and clients (i.e., QEPs). In the years since its adoption,

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