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Expert Analysis

CFTC Relief For Foreign CPOs Based On Incorrect Reasoning

Law360, New York ( March 14, 2016, 3:36 PM EDT) -- The Division of Swap Dealer and Intermediary Oversight (DSIO) of the U.S. Commodity Futures Trading Commission recently issued a no-action letter[1] to provide certain intermediaries located outside of the United States with relief from registration requirements as a commodity pool operator (CPO), commodity trading adviser (CTA) or introducing broker (IB). The foreign intermediaries covered by the release are those that would be eligible for registration relief under CFTC Regulation 3.10(c)(3)(i) but for their failure to meet the condition that commodity interest transactions be submitted for clearing through a futures commission merchant (FCM)....

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