Recently, the CFTC issued rules to eliminate the 4.13(a)(4) exemption and add marketing and trading restrictions to the 4.5 exemption that exempted certain pool operators from registering as a CPO. Although the effective date of the 4.5 changes is still pending, entities that currently hold 4.13(a)(4) exemptions will only remain exempt until December 31, 2012…....
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