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Effective September 8 - New CFTC Requirement for CPOs Who Rely on the De Minimis Exemption for Private Funds

The U.S. Commodity Futures Trading Commission (“CFTC”) has amended (the “Amendment”) the requirements to qualify for an exemption from registration as a commodity pool operator (“CPO”) under certain CFTC Rules including Rule 4.13(a)(3), which is commonly known as the de minimis exemption for private funds (each an “Exemption”).

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U.S. Treasury Proposal Excludes Certain Foreign Exchange Derivatives from “Swap” Definition

Practices: Private Funds, Hedge Funds, Investment Management

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