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Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors
The Commodity Futures Trading Commission (CFTC or Commission) is proposing amendments to its regulations to permit commodity pool operators (CPOs) that only solicit and/or accept ...
Family offices can avoid SEC registration provided they stay within the confines of Advisers Act rule 202(a)(11)(G)-1 (family offices). This means they can’t hold themselves ...
Consistent with CFTC Staff Letters 12-37 and 14-143, and its past practice in this area, the Division granted no-action relief from CPO and CTA registration ...
It’s permissible for “non-key employees” of family office advisers to engage in “purely administrative duties,” such as preparing and filing taxes for a trust, keeping ...
Division staff has been asked whether certain trust decision-making powers can be bifurcated between a key employee and a non-key employee. Division staff has also
been ...
This no-action letter from 2014 gives family offices the ability not to register as commodity trading advisors. The SEC has given certain family offices the ...
Consistent with CFTC Staff Letter 12-37, the Division of Swap Dealer and Intermediary Oversight provided no-action relief from commodity trading advisor registration to family offices ...
(a) Exclusion. A family office, as defined in this section, shall not be considered to be an investment adviser for purpose of the Act. (b) ...
The Investment Advisers Act of 1940Section 202 -- DefinitionsWhen used in this title, unless the context otherwise requires, the following definitions shall apply:"Assignment" includes any ...
Two families, whose patriarchs have been business partners of a large, publicly traded U.S. retailer since the company's founding over forty years ago, requested no-action ...