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Recent CFTC Enforcement Action against Non-U.S. Fund Manager for Violation of U.S. Position Limits Highlights Traps for Unwary

On July 2, 2019, the United States Commodity Futures Trading Commission (“CFTC”) issued an order (the “Order”) filing and simultaneously settling charges against Elephas Investment Management Limited (“Elephas”), a hedge fund manager located in Hong Kong that is not registered with the CFTC, for violating speculative position limits on wheat futures. A simultaneous action was brought and settled by the Chicago Board of Trade (“CBOT”).

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2014 Mutual Funds and Investment Management Conference

Time to Read: 1 minutes Practices: Investment Management

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Ropes & Gray’s memorandum summarizing the 2014 Mutual Funds and Investment Management Conference sponsored by the ICI is available above. The Conference included sessions that discussed the following regulatory developments, among others:
  • Short-term initiatives of the Securities and Exchange Commission (“SEC”) include potential changes to Form N-SAR and rulemaking relating to money market reform, variable annuity disclosure, target date retirement funds, exchange-traded funds, and say on pay.
  • FINRA will conduct a refresh review of its rules, including its advertising rules.
  • CFTC rules requiring mandatory clearing of non-deliverable FX forwards and options are expected to be proposed in May.
  • The SEC will conduct a national sweep exam of alternative funds, beginning this summer, that initially will target 15-20 fund complexes and will focus on compliance, liquidity, leverage, and board oversight.

If you would like to discuss a specific session, or any other aspect of the conference, please contact any of the lawyers listed on the back cover of the memorandum or the Ropes & Gray lawyer with whom you regularly work.

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