Dechert Comment Letter Regarding CFTC Proposed Rulemaking in Respect of CFTC Regulations 4.13(a)(3) and (a)(4)

April 13, 2011
Dechert financial services partners George J. Mazin and M. Holland West and counsel Matthew K. Kerfoot authored this comment letter to the Commodity Futures Trading Commission regarding its proposal to rescind the exemptions from registration widely used by private investment funds for commodity pool operators (“CPOs”) offering commodity pools to sophisticated, creditworthy and/or otherwise regulated investors under CFTC Regulations 4.13(a)(3) and (a)(4). The proposal also seeks to further expand existing compliance obligations for certain CPOs and commodity trading advisors.