US CFTC ISSUES ADVISORY APPLICABLE TO CPOS OF OFFSHORE COMMODITY POOLS

Abstract

This paper first generally describes the requirements under US federal law to register as a commodity pool operator (CPO), and the disclosure, reporting and record keeping obligations which normally apply to registered CPOs. It then discusses in detail two particular sources of relief from certain of these disclosure, reporting and record keeping obligations — an Advisory issued by the US Commodity Futures Trading Commission (CFTC) on 11th April, 1996, and CFTC Rule 4.7 — and compares the requirements to qualify for, and relief available under, the Advisory and CFTC Rule 4.7.