Cadwalader allows sharing content.
Email to a friend or colleague:
Upon effectiveness of the U.S. Commodity Futures Trading Commission (“CFTC”) final rules defining “swaps” under the Dodd-Frank Act, entities associated with securitization transactions may be required to register as commodity pool operators (“CPOs”) and/or commodity trading advisors (“CTAs”). Absent exemptive relief, these registration requirements will apply irrespective of whether the “swaps” are subject to mandatory clearing under the Dodd-Frank Act. Based on the Dodd-Frank Act and current CFTC regulations, certain entities associated with public and certain private securitization transactions are not exempt and may have to register as CPOs and/or CTAs.