Comment Text:
The Commodity Futures Trading Commission (“CFTC” or “Commission”) has requested comments on the proposed rule set out in Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors, Notice of Proposed Rulemaking, 83 FR 52902 (October 18, 2018) (the “Proposed Rule”), providing registration relief for various persons who, without the implementation of the Proposed Rule, might otherwise be required to register as a Commodity Pool Operator (“CPO”) and/or Commodity Trading Advisor (“CTA”).
Norton Rose Fulbright is a global law firm. We provide the world’s preeminent corporations and financial institutions with a full business law service. We have more than 4,000 lawyers and other legal staff based in Europe, the United States, Canada, Latin America, Asia, Australia, the Middle East and Africa. We have many family office clients.
We support the adoption of the Proposed Rule insofar as it relates to family offices for the reasons set forth in and with the modifications proposed in the comment letter submitted by The Private Investor Coalition, Inc. on November 28, 2018.
Thank you for your consideration of these comments.
