Recently, the CFTC issued rules to eliminate the 4.13(a)(4) exemption and add marketing and trading restrictions to the 4.5 exemption that exempted certain pool operators from registering as a CPO. Although the effective date of the 4.5 changes is still pending, entities that currently hold 4.13(a)(4) exemptions will only remain exempt until December 31, 2012. Prior to that date, exempt CPOs will need to consider whether their trading activities will qualify for an alternative exemption or whether they will need to become registered as a CPO. Another of the recently adopted changes requires an annual reaffirmation of the remaining exemptions….