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Securities Litigation Involving Venture Capital Firms And Vol. 53 No.15 September 16, 2020 RECENT DEVELOPMENTS AFFECTING COMMODITY POOL OPERATORS AND COMMODITY TRADING ADVISORS In this article, the authors lay out the various recent changes the CFTC has made to simplify certain regulations applicable to CPOs and CTAs and to close a perceived regulatory gap, as well as reporting relief measures that the CFTC and the NFA have afforded to CPOs and CTAs. They also discuss branch office registration relief for firms with APs temporarily away from their firm’s main office and fingerprinting relief when obtaining fingerprint cards would be difficult or dangerous. They close with a description of the CFTC’s proposed amendments related to its periodic systemic risk reports. By Philip T. Hinkle and Audrey Wagner * Late 2019 and the first half of 2020 saw several CFTC rules could be simplified and made less costly for regulatory developments relevant to commodity pool compliance.2 operators (“CPOs”) and commodity trading advisors (“CTAs”), some resulting from the Commodity Futures As the COVID-19 pandemic, and related market and Trading Commission planned rulemaking agenda while business disruptions swept the world, the CFTC others came as a result of the CFTC staff and the provided various reporting relief to CPOs and CTAs, National Futures Association (“NFA”) response to which relief the NFA echoed. In addition, the NFA challenges the COVID-19 pandemic created for CPO provided branch office registration relief to firms with and CTA registration and ongoing compliance. In Associated Persons (“APs”) temporarily in alternate December 2019, the CFTC finalized some, but not all, of locations from their firm’s main business address. The the rule amendments to its Part 4 rules that it had CFTC and NFA also provided fingerprinting relief to proposed in October 2018 under former CFTC Chairman allow registrations of associated persons and listing of Christopher Giancarlo’s Project KISS initiative.1 The principals to continue despite social distancing and lock- Project KISS initiative was intended to examine where down efforts that would make obtaining fingerprint cards for personnel difficult and potentially dangerous. ———————————————————— ———————————————————— 1 Registration and Compliance Requirements for Commodity Pool 2 CFTC Requests Public Input on Simplifying Rules, CFTC Press Operators and Commodity Trading Advisors, 83 Fed. Reg. Release (May 3, 2017), available at https://www.cftc.gov/ 52902 (Oct. 18, 2018). PressRoom/PressReleases/pr7555-17. PHILIP T. HINKLE is a partner in the Washington, D.C. office FORTHCOMING of Dechert LLP. He regularly advises U.S. financial institutions ● SEC ENFORCEMENT AND TRENDS on a variety of investment management and commodities and derivatives matters. AUDREY WAGNER is counsel in the Washington, D.C. office of the firm. She focuses her practice on diverse investment management, commodities, and derivatives matters. Their e-mail addresses are [email protected] and [email protected]. September 16, 2020 Page 179 RSCR Publications LLC Published 22 times a year by RSCR Publications LLC. Executive and Editorial Offices, 2628 Broadway, Suite 29A, New York, NY 10025-5055. Subscription rates: $1,197 per year in U.S., Canada, and Mexico; $1,262 elsewhere (air mail delivered). A 15% discount is available for qualified academic libraries and full-time teachers. For subscription information and customer service call (937) 387-0473 or visit our website at www.rscrpubs.com. General Editor: Michael O. Finkelstein; tel. 212-876-1715; e-mail [email protected]. Associate Editor: Sarah Strauss Himmelfarb; tel. 301-294-6233; e-mail [email protected]. To submit a manuscript for publication contact Ms. Himmelfarb. Copyright © 2020 by RSCR Publications LLC. ISSN: 0884-2426. All rights reserved. Reproduction in whole or in part prohibited except by permission. For permission, contact Copyright Clearance Center at www.copyright.com. The Review of Securities & Commodities Regulation does not guarantee the accuracy, adequacy, or completeness of any information and is not responsible for any errors or omissions, or for the results obtained from the use of such information. Finally, the CFTC proceeded with proposing certain • provided relief from filing CFTC Forms CPO-PQR amendments related to its periodic systemic risk reports and CTA-PR for certain classes of registered CPOs on Form CPO-PQR. This article reviews each of these and CTAs. developments in turn. These rule changes were intended to simplify certain CFTC PART 4 RULE AMENDMENTS regulations applicable to CPOs and CTAs. However, some of the amendments still required action on the part As noted above, the CFTC published in the Federal of a CPO or CTA in order to avail itself of the benefits Register on December 10, 2019 several amendments to of the relevant amendments, as described herein. the regulatory framework applicable to certain CPOs and CTAs that the CFTC had initially proposed in October Business Development Companies 2018.3 The amendments: Part of this rulemaking effort directly affected • codified a CPO exclusion for investment advisers of investment companies that have elected to be exempt business development companies (“BDCs”) that had from registration under the 1940 Act as a BDC. been relying on CFTC staff no-action relief, Specifically, the CFTC amended Rule 4.5(a)(1) and requiring a CFTC Rule 4.5 notice of exclusion filing (b)(1) to codify a CPO exclusion under CFTC No- with the NFA as soon as was practicable following Action Letter No. 12-40 for investment advisers to January 9, 2020; BDCs that trade in commodity interests. • clarified that the CPO exclusion for an entity The term “commodity interest” includes all futures, operating as an investment company registered options on futures, commodity options, and swaps. under the Investment Company Act of 1940 is BDCs generally do not trade more than a de minimis available to the registered fund’s investment adviser; amount of commodity interests. However, the commodity interests that they do trade (typically interest • provided a CPO and CTA registration exemption for rate and currency swaps) cause such BDCs to be deemed family offices and/or family clients as defined under to be commodity pools pursuant to the CFTC’s Securities and Exchange Commission regulations; regulations, especially since swaps came under the CFTC’s regulatory jurisdiction in 2012 following the • codified relief permitting general solicitation with 2008 financial crisis. respect to commodity pools operated by CPOs claiming relief under CFTC Rules 4.7(b) and New Filing Requirement for BDCs. The amendments 4.13(a)(3), as contemplated by the Jumpstart Our to CFTC Rule 4.5 superseded Letter 12-40. As a result, Business Startups Act (“JOBS” Act) and related investment advisers to BDCs that currently trade SEC rules; and commodity interests to a de minimis extent were required to file an electronic notice of exclusion with the NFA as soon as practicable after these amendments went ———————————————————— into effect after January 9, 2020.4 Going forward, 3 Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors: Registered ———————————————————— Investment Companies, Business Development Companies, and 4 CFTC Rule 4.5(c)(2)(iii) requires that the investment adviser Definition of Reporting Person, 84 Fed. Reg. 67343 (Dec. 10, claiming the exclusion under CFTC Rule 4.5(b)(1) must operate 2019); Registration and Compliance Requirements for the BDC in such a manner that the commodity interest trading Commodity Pool Operators and Commodity Trading Advisors: of the BDC, other than for bona fide hedging purposes, meets Family Offices and Exempt CPOs, 84 Fed. Reg. 67355 one of two de minimis trading tests and the BDC may not (Dec. 10, 2019). Although proposed together in October 2018, market participations in the BDC to the public as a commodity the CFTC published the rule amendments in these two separate pool or as a vehicle for trading in commodity interests. Under releases. the first de minimis commodity interest trading test, the initial September 16, 2020 Page 180 investment advisers to new BDCs trading commodity Registered Investment Companies interests and existing BDCs that begin trading commodity interests will need to file the electronic The CFTC amended Rule 4.5(a)(1) to change the notice of exclusion with the NFA prior to operating in entity that is excluded from the definition of CPO from this capacity. “the investment company registered as such under” the 1940 Act to the investment adviser to the registered New Annual Reaffirmation Requirement for BDCs. fund. This change aligns the exclusion with the CFTC’s After filing an initial notice of exclusion, investment stated expectation that the registered fund’s investment advisers to BDCs will be required to reaffirm the adviser would be the appropriate entity to operate, in a electronic notice of exclusion with the NFA annually, registered CPO capacity, a registered fund that cannot within 60 days following each calendar year-end. This meet the conditions of the CFTC Rule 4.5 exclusion.5 is a noteworthy change for BDCs, as the relief under New CFTC Rule 4.5 exclusion notices that are filed Letter 12-40 did not require annual reaffirmation. electronically with the NFA on or after the January 9, 2020 effective date of the rule change need to identify Historically, the NFA has sent e-mail reminders the investment adviser (rather than the registered fund) regarding the reaffirmation process to entities relying on as the excluded CPO. CPO or CTA registration exclusions and/or exemptions that are subject to reaffirmation. These reminders CFTC Rule 4.5(a)(1) historically has identified the typically have been sent in early December of each year. registered fund as the excluded CPO, and CFTC Rule When setting up a filing account with the NFA, 4.5(b)(1) identified the “qualifying entity” as the investment advisers to BDCs may wish to provide a registered fund as well.
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