*Letters

NFA Compliance Rule 2-46

Published on:
April 10, 2013
Issue:
Committee:

The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Company Institute (ICI) provide confirmation to the National Futures Association (NFA) regarding the application of NFA Compliance Rule 2-46 to Commodity Pool Operators (CPOs) of registered investment companies (registered funds) that trade in commodity interests through wholly-owned subsidiaries (known as controlled foreign corporations or CFCs). Specifically, SIFMA AMG and ICI request that NFA confirm that CPOs to registered funds that consolidate the CFC with the registered fund for financial reporting purposes may defer the reporting obligation under Compliance Rule 2-46 for the CFC until the first applicable reporting period ending after the compliance date of the Commodity Futures Trading Commission (CFTC’s) final harmonization rule.

The groups also sent a letter on the issue to the CFTC on April 10, 2013.

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.