Dechert Comment Letter Regarding the Final Rules Amending Part 4 of the CFTC’s Regulations [RIN number 3038-AD30]

April 05, 2012
Dechert issued this comment letter in response to the final rules (“Final Rules”) adopted on February 9, 2012 by the Commodity Futures Trading Commission (“CFTC”) under the Commodity Exchange Act as amended (“CEA”) in anticipation of the scheduled April 24, 2012 effective date of the Final Rules. The Final Rules modify and eliminate certain CFTC registration exclusions and exemptions widely used by sponsors of investment companies registered under the Investment Company Act of 1940 as amended (“1940 Act”) (“mutual funds”) as well as private investment funds, and adopt new forms for reporting by commodity pool operators and commodity trading advisors.