For presentation materials, click here.

The CFTC and the SEC appear to have put their disagreements behind them, at least for now. In August, the CFTC finalized its rules to harmonize the compliance obligations of investment advisers of registered investment companies that are commodity pools. Contemporaneously, the SEC’s Division of Investment Management published guidance for registered funds that use derivatives. We will provide an overview of the CFTC’s final rules, the SEC’s guidance, compliance dates, and the implications for funds that use derivatives and their advisers.