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CFTC Staff Partially Reinstate CPO Exemption for RIAs

By Matthew Bisanz, Adam D. Kanter, Elizabeth McClain, Anna T. Pinedo & Jodi Erlandsen on December 26, 2025
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On December 19, the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”) issued no-action relief from commodity pool operator registration for SEC-registered investment advisers to certain private funds. This relief effectively reinstates the registration exemption previously provided by Rule 4.13(a)(4) for managers to private funds offered solely to qualified eligible persons, subject to certain additional conditions. In this Legal Update, we provide background on CFTC staff’s no-action relief and key takeaways.

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Photo of Adam D. Kanter Adam D. Kanter
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Photo of Anna T. Pinedo Anna T. Pinedo

Anna Pinedo is a partner in Mayer Brown’s New York office and a member of the Corporate & Securities practice. She concentrates her practice on securities and derivatives. Anna represents issuers, investment banks/financial intermediaries and investors in financing transactions, including public offerings and…

Anna Pinedo is a partner in Mayer Brown’s New York office and a member of the Corporate & Securities practice. She concentrates her practice on securities and derivatives. Anna represents issuers, investment banks/financial intermediaries and investors in financing transactions, including public offerings and private placements of equity and debt securities, as well as structured notes and other hybrid and structured products.

Read Anna’s full bio.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Free Writings + Perspectives
  • Organization:
    Mayer Brown
  • Article: View Original Source

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