by Lawrence T. Eckert, Associate
Originally published in: SRZ Client ALERT, November 2002
The Commodity Futures Trading Commission (CFTC) issued an Advance Notice of Proposed Rulemaking (ANPR) which, among other things, includes "embedded no-action relief" (no-action relief) that provides temporary relief from registration as a commodity pool operator (CPO) and commodity trading advisor (CTA) under certain circumstances. The relief is "temporary" in that it will be superseded by any final action taken by the CFTC as a result of the ANPR. In the event a final rulemaking by the CFTC differs from the no-action relief, the CFTC indicated that persons relying on the no-action relief will be provided with sufficient time to comply with any final rule.
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© 2002 Schulte Roth & Zabel LLP
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