By DrinkerBiddle
On September 9, 2014, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (CFTC) issued an exemptive letter (the JOBS Act Exemptive Letter) for private fund managers relying on exemptions from registration as commodity pool operators (CPOs) with the CFTC. This relief harmonizes the CFTC’s CPO exemptions with the 2013 final rules issued by the Securities and Exchange Commission (SEC) relating to offerings exempt from registration under the Securities Act of 1933 (Securities Act) as required by the Jumpstart Our Business Startups Act of 2012 (JOBS Act).