While the Commodity Exchange Act (NYSE:CEA) generally requires CTA and CPO firms to register, there are some important exemptions from its registration provisions. exemption requires interests in the fund to be exempt from registration under the Securities Act. Exemption Filing Each CPO or CTA claiming an exemption from registration under the rules above must annually file a notice identifying which exemption it is relying on. A CTA that is registered, but directs only the accounts of commodity pools for which it is registered as a CPO and, though registered, complies with Rule 4.14(a)(4); A CTA that is registered, but directs only the accounts of commodity pools for which it is exempt from registration as a CPO, and though registered, complies with Rule 4.14(a)(5). Family Offices: New Regulations 13(a)(6) and 4.14(a)(11) were adopted codifying relief previously granted to family offices from commodity pool operator (CPO) and commodity trading advisor (CTA) registration through CFTC Letters 12–37 and 14–143. CTA and CPO Registration Exemptions – while the Commodities Exchange Act will generally require CTA and CPO firms to register with the CFTC, there are some important exemptions from the registration provisions. The CFTC declined to take up industry requests to similarly expand relief from CTA registration for non-U.S. CTAs, although it did slightly expand the scope of the CTA registration exemption to allow CTAs located outside the U.S. to have clients that are “international financial institutions” (e.g., the International Monetary Fund). Page 1 of 1 TD Ameritrade Futures & Forex LLC 144 W. Chicago Ave. Suite fi44 ˜ Chicago, IL 14125-ff209 Phone: 99-52-fffi4 ˜ Fax: 99-52-ffff To Whom It May Concern: The undersigned hereby represents that he is exempt from the registration as a Commodity Trading Advisor with The Commodity Firms must then visit NFA’s Exemptions Filing System (under the Electronic Filings tab on NFA’s website) to affirm each exemption or exclusion. The CFTC approved final amendments to the CPO and CTA registration exemptions and exclusions in Part 4 of its regulations (here and here) on November 25, … This … Individuals applying for NFA membership as a sole proprietor FCM, RFED, IB, CPO, CTA, or for registration as CTA Qualification; Revised CTA Examination; Level 7 Apprenticeship; ATT CTA Tax Pathway; ACA CTA Joint Programme; CA CTA Joint Programme; Registration. Review this article to see if your firm might be able to claim an exemption from the registration provisions. What Exam requirements are associated with registration? Because the Persons claiming exemptions from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA) must affirm their exemptions by March 1, 2018. Private funds that meet the requirements of the Rule 4.13(a)(4) exemption currently are permitted to undertake unlimited trading in Commodity Interests, whether for hedging or speculative purposes. The Commission proposed amendments to Regulations 4.13 and 4.14 that would establish CPO and CTA registration exemptions for persons meeting the definition of “family office,” (the Family Offices) consistent with the regulatory exclusion from the definition of “investment adviser,” for Family Offices adopted by the SEC in 2012. Firms operating pursuant to an exemption or exclusion from CPO or CTA registration should confirm that they continue to comply with the requirements of the applicable exemption or exclusion.
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