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ARTICLE · 28 JANUARY 2026

Financial Markets And Funds Quick Take | Issue 46

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Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds.

United StatesFinance and Banking

Katten's Financial Markets and FundsQuick Takeis a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds.

To read more issues of Katten's Financial Markets and FundsQuick Take, pleaseclick here.

CFTC No-Action Reinstates Broad Registration Exemption for Institutional CPOs, Pending Further Action

By Christian Hennion

On December 19, the Staff of the CFTC's Markets Participant Division published a new no-action letter – CFTC Staff Letter 25-50 – which creates an exemption from commodity pool operator (CPO) registration for operators of privately-offered pools owned solely by "qualified eligible persons"(QEPs), as defined in CFTC rules. In particular, this exemption is available to CPOs registered as investment advisers with the SEC with respect to qualifying commodity pools reported in the adviser's Form PF filings. Read about the registration exemption.

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