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hflawreport.com

Many in the private funds industry have reacted positively to the Market Participants Division of the CFTC’s issuance of December 19, 2025, No‑Action Letter 25‑50 (Letter) that restores an exemption from CFTC registration for commodity pool operators (CPOs) and commodity trading advisors (CTAs). But as welcome as it may be, the Letter was not drafted with all CPOs and CTAs in mind. Depending on their operations, strategy and risk exposure, some will find it to be of greater utility than others. “Stepping down,” i.e., relying on the no‑action relief and/or deregistering, comes with broad disclosure responsibilities. Moreover, whether to step down, before rulemaking codifies the Letter into law, requires careful consideration. This article, the second in a two-part series, considers which types of asset managers are the likeliest beneficiaries of the Letter’s relief; addresses the reporting and disclosure requirements of those that opt to deregister to take advantage of the new relief; and weighs the pros and cons of taking action now in the absence of formal rulemaking. The first article explained the background of and rationale for the CFTC’s no‑action position and summarized the Letter. For more on the CFTC’s revisitation of legal precedent, see “CFTC Advisory on Self-Reporting, Cooperation and Remediation Overhauls Years of Guidance” (Mar. 27, 2025).