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CFTC Cracks Down on Insider Trading
CTA Intelligence
November 2018
On Sept. 28, 2018, the CFTC took two new steps in an ongoing process of expanding its enforcement role and promoting the growth of traditional insider trading principles in the commodities derivatives markets. The CFTC filed a civil enforcement action against an introducing broker and one of its registered associated persons, alleging misuse of material, non-public information in the commodities futures markets. Even more significantly, the CFTC announced the formation of a new Insider Trading and Information Protection Task Force to enforce its insider trading rules. The CFTC’s increased focus on this area, particularly given conspicuous budgetary limitations, signals that preventing insider trading is now a CFTC priority. In this article, partner Harry Davis and former Schulte lawyer Brian Daly discuss in more the detail the enforcement action and the newly formed task force.
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Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]
Alerts
On March 1, 2024, New York Governor Kathy Hochul signed into law an amended version of the New York LLC Transparency Act (“NYLTA”),[1] requiring certain limited liability companies (“LLCs”) formed or authorized to do business in New York (each, a “NY Reporting Company”) to file a beneficial ownership information (“BOI”) report with the NY Department of State (“NY DOS”). Each NY Reporting Company will be required to disclose on its BOI report identifying information pertaining to each individual who directly or indirectly exercises substantial control or owns or controls 25 percent or more of the ownership interests of a NY Reporting Company (each, a “Beneficial Owner”) and the individuals involved in the NY Reporting Company’s formation or registration to do business in New York (each, an “Applicant”). Information reported to NY DOS will be maintained in a private database not accessible to the public. The NYLTA goes into effect on Jan. 1, 2026 and requires the NY DOS to promulgate regulations implementing the legislation.
Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]