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CFTC Proposes Rule Amendments to Expand Exemptions for Non-U.S. Commodity Pool Operators

On May 28, 2020, the Commodity Futures Trading Commission (“CFTC”) approved proposed amendments to CFTC Regulation 3.10(c), which currently provides a jurisdictional based registration exemption for non-U.S. commodity pool operators (“CPOs”) that operate non-U.S. funds with non-U.S. investors (the “Proposed Amendments”). Historically, the CPO registration exemption available under Regulation 3.10(c)(3) has presented challenges for non-U.S.…

Client Alerts | June 9, 2020 | Derivatives | Investment Management

NY Fed Announces First Subscription and Closing Dates for TALF 2.0 and Provides Expanded FAQ Responses

On May 20, 2020, the Federal Reserve Bank of New York (the “New York Fed”) announced June 17, 2020 as the first subscription date and June 25, 2020 as the first closing date of the Term Asset-Backed Loan Facility (“TALF 2.0”). The Board of Governors of the Federal Reserve System first authorized TALF 2.0 on March…

Client Alerts | May 21, 2020 | Investment Management | Special Situations and Credit

COVID-19: Temporary Form ADV and Form PF Relief Period Extended to June 30, 2020

On March 25, 2020, the U.S. Securities and Exchange Commission (“SEC”) issued an exemptive order (the “Updated Order”1) expanding the temporary regulatory relief from certain Form ADV and Form PF requirements previously granted under its March 13, 2020 exemptive order (the “Original Order”) to investment advisers whose operations may be disrupted by the outbreak of…

Client Alerts | April 2, 2020 | Investment Management