Housekeeping, Reminders and Updates – July 2017

Written by:      Mark E. Ruddy, Esq. Jessica I. Brown, CAMS Commodity Trading Advisors (“CTAs”) Third-Party Record Keeping Relief CTAs now have the ability to request relief from certain Commodity Futures Trading Commission (“CFTC”) Regulation 4.33 and 4.7(c)(2) record-keeping requirements. CFTC Exemptive Letter No 17-24 provided CTAs relief from the requirement that books and records must be kept at the registrant’s main office. Letter 17-24, issued by the Division of Swap Dealers and Intermediary Oversight (“DSIO”), allows CTAs to submit a request for relief so that the firm may use a third-party record keeper to comply with Regulations 4.33 and 4.7(c)(2)….

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