CFTC Issues Far-Reaching Proposal to Amend Registration Requirements for CPOs and CTAs

skyscrapers upward view symmetry modern corporate architecture cityskyscrapers upward view symmetry modern corporate architecture city

CFTC Issues Far-Reaching Proposal to Amend Registration Requirements for CPOs and CTAs

October 22, 2026

United States
United States
United States
Hedge Fund Law Report 

Partner Raymond Ramirez discusses the CFTC's proposed Regulation 4.13(a)(4) that could ease registration requirements for SEC-registered investment advisers that operate commodity pools for qualified eligible persons.

He discusses the proposal’s history and the considerations that led to this recent development, including signaling a shift toward reducing duplicative regulatory requirements.

"When the CFTC rescinded its exemption for private funds in 2012, market participants had to go out and find other exemptions. So the CFTC is essentially bringing the rescinded 2012 exemption back, although with some differences," Ray said.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Services

Industries

Key contacts

rayramirez@eversheds-sutherland.com

Raymond A. Ramirez

Partner

Washington, DC, United States

Latest Insights

Latest News

Latest Events

  • hybrid
  • virtual | November 17, 2026
  • in-person | November 18, 2026
  • virtual | November 24, 2026
Resilient Cities and Built Environment

legal updates

November 13, 2026

COP31: Leaders’ Summit | Resilient Cities and Built Environment 

zero waste new pic

legal updates

November 12, 2026

EV charging COP31

legal updates

November 11, 2026

tracker image - Algorithmic

legal updates

November 11, 2026

© Eversheds Sutherland 2026. All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website.