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Analysis & Insights

NFA / CFTC Compliance Support for Independent Governance Professionals and Emerging CTAs

23 Mar 2021

Many hedge funds, including managed accounts, investing in commodity interests may be subject to Volcker Rule requirements and, transaction dependent, could be considered a commodity pool. Independent governance professionals of the commodity pool are deemed "commodity pool operators" of the investment vehicles they govern and, to satisfy certain requirements, may opt to delegate certain responsibilities to the investment advisor.  However, with a growing number of investment advisors and platform managers narrowing their scope of services to focus on their core competencies, many may need to have a third-party assume this role.

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