This memorandum addresses the Commodity Futures Trading Commission’s (CFTC) final rule on compliance obligations for registered investment companies whose advisers are required to register as commodity pool operators (CPOs) pursuant to recent changes to CFTC Rule 4.5. Under the final rule, the CFTC has adopted a substituted compliance regime for CPOs of registered investment companies, which generally allows such entities to meet CFTC requirements through adherence to the Securities and Exchange Commission statutory and regulatory compliance regime, subject to certain notice and other requirements.
