JP Bruynes Discusses CFTC Guidance on Commodity Pool Operators

JP Bruynes, a partner in Akin Gump’s investment management practice, was quoted in a Compliance Intelligence article that addresses recent guidance from the Commodity Futures Trading Commission (CFTC) on requirements for commodity pool operators.

Bruynes noted that people had been “up in arms” because of what they thought was inconsistent guidance and criteria coming from the commission. In addition to discussing the impact of a 2013 National Futures Association review of financial statements, he said “firms who do not qualify for all the criteria [in the new CFTC guidance] still need to file their own customized no-action letters with the CFTC.” He also added that “firms need to closely examine the criteria to see if they qualify.”