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CFTC Staff Partially Reinstate CPO Exemption for RIAs

By Matthew Bisanz, Adam D. Kanter, Elizabeth McClain, Anna T. Pinedo & Jodi Erlandsen on December 26, 2025

On December 19, the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”) issued no-action relief from commodity pool operator registration for SEC-registered investment advisers to certain private funds. This relief effectively reinstates the registration exemption previously provided by Rule 4.13(a)(4) for managers to private funds offered solely to qualified eligible persons, subject to certain additional conditions. In this Legal Update, we provide background on CFTC staff’s no-action relief and key takeaways.

Read this Legal Update.

  • Posted in:
    Corporate & Commercial, Securities
  • Blog:
    Free Writings + Perspectives
  • Organization:
    Mayer Brown
  • Article: View Original Source

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