On October 2, 2023, the Commodity Futures Trading Commission (CFTC) published a notice of proposed rulemaking (NPRM), which includes a proposal to amend portions of 17 C.F.R. § 4.7. Under Regulation 4.7, commodity pool operators (CPOs) and commodity trading advisors (CTAs) are exempt from certain disclosure, reporting, and recordkeeping requirements, so long as the “prospective and actual pool participants and/or advisory services are restricted to individuals and entities considered ‘Qualified Eligible Persons’” (QEPs).Continue Reading CFTC Proposes Amendments to Regulation 4.7 Exemption
DJ Mills is an associate within the firm's Financial Services practice group and centers his practice on emerging and established fintech companies, with an emphasis on the digital asset custody space. He assists clients with a broad range of regulatory and transactional matters, including those that implicate money services, securities, and banking law.