News & Media

A Pool Too Big for a FCM or a Broker-Dealer, Futures & Derivatives Law Report, Vol. 22, No. 5

Broad definitions of “commodity pool operator” and “commodity trading adviser”, together with the very broad interpretations of these terms by the CFTC staff, has led to the “inadvertent pool” problem for many registered broker-dealers and futures commission merchants (“FCM”) engaged in proprietary trading activities. These problems have increased significantly over the last five years as […]

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