Philip T. Hinkle
Washington, D.C. +1 202 261 3460
The first two months of 2017 present several important new regulatory deadlines potentially affecting all asset managers that trade derivatives subject to U.S. regulation. Certain deadlines potentially will apply to all derivatives traders whether or not the asset manager is a member of the National Futures Association and registered with the U.S. Commodity Futures Trading Commission as a commodity pool operator (CPO) or commodity trading adviser (CTA).
This article focuses on specific new deadlines and several developments implicating regulations already in effect, which will require advance planning (including business-level input) and, in some cases, could cause trading disruptions if deadlines are not met.