Cadwalader allows sharing content.
Email to a friend or colleague:
From
To
Subject
Email The Dodd-Frank Act’s expansion of the definition of “commodity pool” to include any form of enterprise operated for the purpose of trading in “swaps,” coupled with the Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”) recently adopting an expansive definition of the term “swap” for purposes of the Dodd-Frank Act and the Commodity Exchange Act creates uncertainty regarding whether issuers of insurance linked securities are commodity pools that would require the registration of commodity pool operators (“CPO”) and commodity trading advisors (“CTA”) with the CFTC. https://www.cadwalader.com/resources/clients-friends-memos/the-application-of-commodity-pool-rules-to-insurance-linked-securities