On July 13, the CFTC's Division of Swap Dealer and Intermediary Oversight issued a no-action giving commodity pool operators and commodity trading advisers until December 31 to register with the CFTC to the extent that they have been exempt or excluded from registration but, because of recent amendments to CFTC Regulations 4.13 and 4.5, now need to register and satisfy compliance obligations. Such entities would have had to be registered within 60 days of the publication of rules by the CFTC in February which removed registration exemptions that investment advisers had previously relied upon.
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