Overview
On December 19, 2025, the Commodity Futures Trading Commission (the “CFTC”) issued a no‑action letter (the “No‑Action Letter”) that permits many private fund managers registered with the Securities and Exchange Commission (the “SEC”) to forgo registering with the CFTC as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) or to withdraw existing CPO/CTA
On December 2, 2025, Brian Daly, Director of the Securities and Exchange Commission (the “SEC”) Division of Investment Management (the “Division”), delivered remarks to the American Bar Association outlining the Division’s top priorities under his leadership: deregulation, modernization, democratization, and artificial intelligence (“AI”).
Daly noted that the Division’s agenda will largely be driven by the