March 11, 2013
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New York partner Sean Finley and New York associates Jared Gianatasio and Zachary Bodmer published an article, titled "Life After CPO Registration: Select CFTC and NFA Compliance Obligations that Lie Ahead," in the March-April 2013 issue of Practical Compliance & Risk Management for the Securities Industry, a professional journal published by Wolters Kluwer Financial Services, Inc.
The article highlights several of the significant areas in which the Commodity Futures Trading Commission (CFTC) and National Futures Association regulate “commodity pool operators” (CPOs) and a number of particular requirements that recent CPO registrants should ensure they have accounted for in preparing for life with their new regulators. The article also provides an overview of certain significant regulatory relief that some CPOs may be able to claim, particularly with respect to CFTC disclosure, reporting and recordkeeping obligations.