The CFTC order requires MCM, MCA and MA, all of whom are CFTC registrants, jointly and severally, to pay a $25 million civil monetary penalty and restricts their registrations as Commodity Pool Operators
and/or Commodity Trading Advisors for three years.
They also analyze how the regime applies to securities brokers and dealers, foreign banks, investment companies and advisers, futures commission merchants, and commodity pool operators
and trading advisers.
On September 9, 2014, the staff of the Commodity Futures Trading Commission ( CFTC ) issued an exemptive letter providing relief to commodity pool operators
( CPOs ) from having to comply with certain conditions in CFTC Rules 4.
Jon works exclusively with clients in the financial services industry and has particular expertise in meeting the needs of domestic and offshore investment partnerships/companies, commodity pool operators
and commodity trading advisors, fund of funds, registered investment advisers, broker-dealers, futures commission merchants, regulated investment companies, business development companies and specialty finance companies.
lt;p>Persons who solicit orders, exercise discretionary trading authority and operate pools with respect to retail forex would also be required to register, either as introducing brokers, commodity trading advisors, commodity pool operators
, or as associated persons of such entities.
She advises on all aspects of implementation of the Dodd-Frank Act and its impact on swap dealers, end-users, futures commission merchants, commodity pool operators
and commodity trading advisors.