The U.S. Commodity Futures Trading Commission (CFTC) has proposed a rule that would codify informal registration exemptions that commodity pool operators (CPOs) and commodity trading advisors (CTAs) have been enjoying by virtue of a no-action letter issued in December. The notice of proposed rulemaking, issued in August, is out for comment until Oct. 5.
The no-action letter was issued Dec. 19, 2025, in response to a request from the Managed Funds Association that no enforcement action be taken against any of its members who are primarily private fund managers and fail to register or withdraw from registration as a CPO or CTA.
