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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).

hedgeworld.com

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thehfa.org

The Hedge Fund Association, HFA, is an international not for profit industry trade and nonpartisan lobbying organization devoted to advancing transparency, development and trust in alternative investments.

barclayhedge.com

ION Analytics merges human insight with machine intelligence to transform global capital markets, empowering market participants with information & analytics.

hedgefundmarketing.org

smarter fundraising. stronger investor relationships. supercharge your hedge fund marketing which of the following best describes you? start

turnkeyhedgefunds.com

Explore our Hedge Fund FAQs at Turn Key Hedge Funds. Get answers on accredited investors, private offerings, Regulation D, compliance, and starting a hedge fund. Contact us for expert guidance!

hedgeco.net

HedgeCo Ventures LLC Privacy Policy (2025) - How we collect, use, and protect your information.

marketfolly.com

See what stocks top hedge funds are investing in. Coverage of SEC filings (13D, 13G, 13F, Form 4), hedge fund letters & buyside conferences

cooconnect.com

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