Dechert Files a Comment Letter in Response to the CFTC Rule 4.7 Rule Change Proposals

December 13, 2023

On December 11, 2023, Dechert LLP filed a comment letter in response to the CFTC’s proposed amendments to the regulation of registered CPOs and CTAs whose pool investors and account clients qualify as “qualified eligible persons” under CFTC Rule 4.7.

Capitalizing on Dechert’s extensive practical experience advising registered CPOs and CTAs, private fund advisers registered with the SEC and on the regulation of these funds and accounts in European jurisdictions, the comment letter, among other things, highlights the complexity of complying with the proposed rule amendments concurrently with other applicable regulations. The comment letter also makes suggestions for how the CFTC could achieve its stated aims without unduly burdening this segment of the buy-side commodity interest markets. However, on the whole, the letter encourages the CFTC to study the issues further and engage with affected market intermediaries, pool investors, and account clients before proceeding with any final rulemaking.

Read “Dechert LLP Comment Letter – Commodity Pool Operators and Commodity Trading Advisors: Proposed Rule Amendments Related to Operation under CFTC Rule 4.7 [RIN 3038-AF25],” authored by Karen Anderberg, Philip Hinkle, Michael McGrath, and Audrey Wagner.

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