Nick Curley
Bitcoin and Digital Asset Infrastructure, Commodity Pools, Investment Advisers and Other Asset Managers, Fund Formation, Investment Funds, Regulatory, Compliance & Corporate Governance

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We advise commodity pool operators (CPOs) and commodity trading advisors (CTAs) on the full range of legal and regulatory issues that arise in the operation of commodity pools and managed accounts trading commodity interests. Our counsel spans commodity pool structuring and formation, as well as securities and commodities regulatory compliance.
The team has extensive experience in registering CPOs and CTAs. Our attorneys advise clients through National Futures Association (NFA) examinations and inquiries, providing practical and strategic advice to address compliance issues.
Additionally, our team advises on the launch and operation of commodity interest vehicles across a variety of structures and regulatory postures, including both CFTC Rule 4.7 exempt pools and non-exempt “filed” funds and accounts. For example, we have experience representing a CPO in the registration process and formation of a filed fund offering a retail forex trading strategy, including the preparation and submission of the disclosure document filed with NFA.
We assist clients in navigating exemption filings, disclosure obligations, and operational best practices tailored to institutional investor expectations. The team also tailors compliance manuals to the unique regulatory and business needs of each client.
In addition, we also review marketing arrangements, trading documentation, derivatives, and prime brokerage arrangements for its commodity pool clients.
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Nick Curley
Bitcoin and Digital Asset Infrastructure, Commodity Pools, Investment Advisers and Other Asset Managers, Fund Formation, Investment Funds, Regulatory, Compliance & Corporate Governance

Gavin Fearey
Bitcoin and Digital Asset Infrastructure, Commodity Pools, Investment Advisers and Other Asset Managers, Investment Funds, Fund Formation, Regulatory, Compliance & Corporate Governance, Securities and Capital Markets

Nicole Kuchera
Investment Advisers and Other Asset Managers, Fund Formation, Commodity Pools, Regulatory, Compliance & Corporate Governance, Securities and Capital Markets
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