The Cabinet updated the " Disclosure, Reporting, and Recordkeeping Requirements" chapter of the Cadwalader Guide to Commodities Regulation. The Guide is applicable to CPOs and CTAs that provide services to public and private commodity pools, including SEC-registered investment companies that are treated as commodity pools under the Commodity Exchange Act.
In addition to providing current materials since this chapter was last revised, the chapter covers:
- amendments adopted by the CFTC in 2017 to facilitate the modernization of storage of electronic records that take advantage of recent enhancements in information technology; and
- new requirements by NFA that require CPOs to design and implement "internal controls" to ensure that the books and records of their commodity pools are current and accurate.
As with previous versions, the updated chapter includes a comprehensive description and analysis of reporting requirements that CPOs and CTAs must provide involving Form CPO-PQR and CTA-PR.
The Cadwalader Cabinet is also introducing three new Topic Pages covering the following topics:
- disclosure requirements for CPOs and CTAs;
- reporting requirements for CPOs and CTAs; and
- recordkeeping requirements for CPOs and CTAs.
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