Excerpt from Practical Guidance

How Commodities Regulations Apply To Investment Advisers

Law360, New York (July 17, 2014, 12:51 PM EDT) -- Many investment advisers also qualify as commodity trading advisers (CTA) and, with respect to the funds they manage, as commodity pool operators (CPO) under the Commodity Exchange Act (CEA). Legal counsel should keep this in mind for any adviser that employs investment strategies involving even de minimis use of swaps, futures, options or other derivatives that fall within the broad definition of "commodity interest" under the CEA....

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