Recent regulatory changes caused by amendments to the Commodity Exchange Act of 1936 by the Dodd-Frank Act may force family offices that have created any pooled investment vehicle falling within the definition of a “commodity pool” to consider whether or not they are required to register, or file a notice for exemption from registration, as a commodity pool operator (“CPO”). This Legal Update discusses the potential issues facing family offices arising from these changes and analyzes certain of the exemptions from CPO registration that may be available to them.

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