Proposed Amendments to Registration and Compliance Requirements for Commodity Pool Operators

The Asset Management Group of SIFMA (SIFMA AMG) provided comments to the Commodity Futures Trading Commission (CFTC) on their Notice of Proposed Rulemaking regarding Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors. SIFMA AMG strongly supported the CFTC’s efforts to simplify the regulatory obligations for CPOs and CTAs, and believes that the great majority of the individual components of the Proposal effectively achieve the Project KISS objectives. However, we believe that certain specific components of the Proposal will, in practice, have the contrary effect, by adding, rather than reducing, regulatory burdens, and by introducing, rather than eliminating, regulatory uncertainty.