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Hedge-Fund Commodity Net Longs Jump to 28-Month High, Led by Wheat, Corn
Bloomberg Hedge-fund managers and other large speculators raised bets on price gains for 20 commodities traded … |
Source: Hedge Fund – Google News
Turn Key Hedge Funds’ Premium Fund Launch Package includes two powerful marketing tools for fund managers: a Marketing Video and Website. Coupled with posting fund information on an SEC-compliant investor/fund matching website, a customized fund Marketing Video and Website provides fund managers with new ways to interface with potential investors, ultimately allowing them to get to know the Fund and fund manager. The TURN KEY COMMODITY TRADING ADVISOR STARTUP for your managed account business provides you with the launch, the operation opportunity, and even IB services to your new CTA. At Turn Key we will: Create the entities, draft operating agreement, and prepare of SS-4 documents for acquisition of federal identification numbers for domestic entities; Secure all NFA/CFTC required approvals; Draft documents necessary and appropriate for a domestic Commodity Trading Advisor (CTA); Draft the CTA Disclosure and related Account Information Documents for managed accounts; Draft confidentiality agreements, Code of Ethics, Disaster Recovery and Data Storage Policy, Email Policy, AML policy, Privacy Policy, Sub Advisor agreements, etc.; Draft Compliance handbook; Draft compensation agreements; Prepare and submit registration documents with the CFTC and NFA as a CTA; and more We shall prepare offering materials consisting of a Disclosure Documents, management agreements and related materials, coil bound on bright white paper with clear plastic covers and black backings; a set of …
How Hedge Fund Traders and CTAs trade momentum
Asian Hedge Fund Closures: Closures jumped 19% this year with industry’s first decline; Asian funds have underperformed rivals in the US and Europe; Report and analysis by Susan Li of Bloomberg News
Are there exemptions from registration as a commodity pool operator for a small hedge fund?
Section 4.7 of Commodity Future Trading Commission Rules provides for certain exemptions from certain requirements with respect to commodity pool operators making offerings to qualified eligible persons or commodity trading advisors with respect to advising qualified eligible persons. Under Section 4.7, the pool operator is exempted from certain disclosure compliance requirements. Specifically, Section 4.21 with respect to required delivery of a pool disclosure document, Section 4.24 with respect to the contents of the disclosure document in general, Section 4.25 with respect to requirements relating to the disclosure of past performance and Section 4.26 with regard to use amendment and filing of a disclosure document. The Section 4.7 exemption is not an exemption from registration as a commodity pool operator or commodity trading advisor.
Section 4.13 generally provides for exemption from registration as a commodity pool operator. Before its amendment in August of 2003, a person was not required to register as a commodity pool operator if the person did not receive any compensation or payment directly or indirectly; operated only one commodity pool at a time; was not otherwise required to register with the commission; and either the person or other person involved with the pools does any advertising in connection with the pool or to the total gross capital contributions for participation units in all pools that are operated, or intends to operate, do not in the aggregate exceed $400,000 and none of the pools operated have more than 15 participants. This is referred to as the “small pool exemption.”
Section 4.13(a)(3) generally provides for exemption from registration as a commodity pool operator where: Aggregate initial margin and premiums do not exceed 5% of the liquidation value of the portfolio and the aggregate net motional value of the positions does not exceed 100% of the liquidation value of the pool portfolio.
Section 4.13(a)(4) generally provides for exemption from registration as a commodity pool operator where: The person reasonably believes, at the time of investment (or, in the case of an existing pool, at the time of conversion to a pool meeting the criteria of paragraph (a)(4) of this section), that: (A) Each natural person participant (including such person’s self-directed employee benefit plan, if any), is a “qualified eligible person,” as that term is defined in section 4.7(a)(2); This exemption can not be claimed if the natural person participants only meet the 4.7(a)(3) portfolio requirement.
As a Fund of Funds you must be aware of each particular states Investment Advisor rules. Many states have exemptions from registration. Also if you intend to invest in futures or commodity funds, you should register with the National Futures Association (NFA) and the Commodity Futures Trading Commission (CFTC) as a Commodity Pool Operator (CPO). This CPO’s associated person must successfully complete the NASD Series 3 examination.
Are there any other types of finders available to issuers in a private placement?
Yes. Rule 3a4-1 provides a non-exclusive safe harbor from the definition of a broker for persons associated with an issuer who are engaged in securities-related activities incident to their duties on behalf of the issuer. See Securities Exchange Act Rel. No. 22172 (June 27, 1985). Employees and possibly individual affiliates of an issuer who are not registered representatives of broker-dealers may be considered “associated persons” for purposes of Rule 3a4-1, in which case they may be exempt from registration and will be permitted to engage in limited sales activities pursuant to the Rule’s safe harbor.
ForEx, hedge funds. Registering with the Commodity Futures Trading Commission
Generally, the Commodity Futures Trading Commission has jurisdiction over transactions in ForEx futures and options contracts offered to retail customers, and the only counterparties that can lawfully enter into these contracts with retail customers on an off-exchange basis are persons that are: (i) registered with the Commission as a futures commission merchant (FCM); (ii) certain affiliates of a registered FCM;, or (iii) otherwise regulated, e.g., as a securities broker-dealer, a bank, a financial institution or an insurance company.
On May 22, 2008, the Congress passed the Farm Bill which, in Title XIII, contains several amendments to the Commodity Exchange Act involving the retail trading of foreign exchange.
Under the CFTC Reauthorization Act, a person operating pool solely trading spot ForEx is not required to register as a CPO at this time (but may be so required in the future upon promulgation of regulations by the CFTC).
As a Fund of Funds you must be aware of each particular states Investment Advisor rules. Many states have exemptions from registration. Also if you intend to invest in futures or commodity funds, you should register with the National Futures Association (NFA) and the Commodity Futures Trading Commission (CFTC) as a Commodity Pool Operator (CPO). This CPO’s associated person must successfully complete the NASD Series 3 examination.
Must a finder be registered as a broker-dealer?
Generally, No. Generally a finder does not have to be registered as a broker-dealer if its finder’s activities are limited. A “broker” under the Securities Exchange Act of 1934 is “any person engaged in the business of effecting transactions in securities for the account of others.” The SEC staff has found activities such as (a) participating in presentations or negotiations, (b) making any recommendations concerning securities, (c) receiving transaction-based compensation, (d) structuring a transaction or making recommendations regarding the nature of the securities, whether to issue securities or to assess the value of securities sold, and (e) continuing involvement in sales of securities to trigger broker-dealer registration obligations. However, a number of states, Texas and California for example, take the position that only a registered representative (broker) may receive kind of compensation.
Are there any other types of finders available to issuers in a private placement?
Yes. Rule 3a4-1 provides a non-exclusive safe harbor from the definition of a broker for persons associated with an issuer who are engaged in securities-related activities incident to their duties on behalf of the issuer. See Securities Exchange Act Rel. No. 22172 (June 27, 1985). Employees and possibly individual affiliates of an issuer who are not registered representatives of broker-dealers may be considered “associated persons” for purposes of Rule 3a4-1, in which case they may be exempt from registration and will be permitted to engage in limited sales activities pursuant to the Rule’s safe harbor.
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