*Letters

Applicability of CPO Amendments to Operators of Fund of Funds

Published on:
August 8, 2013
Issue:
Committee:

The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on application of the de minimis trading tests in Regulation 4.5 and Regulation 4.13 to funds of funds.

SIFMA AMG believes that any formal CFTC guidance

regarding applicability of the amendments to rules 4.5 and 4.13 (CPO Amendments)

to operators of fund of funds should be principles based and consistent with “commercially

reasonable” standards for monitoring compliance.  To that end, SIFMA AMG

recommends certain principles to assist the CFTC in adopting the CPO Amendments

without imposing undue costs and burdens on funds, their managers, and fund

shareholders.

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