O’Melveny’s Clark Quoted in Compliance Intelligence Article on CPO Reform Rules

March 23, 2012

O’Melveny & Myers partner Timothy Clark was quoted in the March 22, 2012, Compliance Intelligence article “Hedge Funds Face CPO Reform Questions, Challenges,” on the changes the Commodity Futures Trading Commission adopted in February and their implications on hedge fund firms who continue to operate in business as commodity pool operators. The majority of the confusion lies over potential dual-registration issues.


“I’m kind of shocked at this point that people aren’t a little more focused on this stuff,” Clark told CI. Clark said he is having to explain to clients the changes and what they mean. Ci writes that generally, the new requirements will come into effect between July and the end of the year, depending on the status and size of the firm in question. All but the larger CPOs will have to file their additional reporting based on their status as of Dec. 31. Larger CPOs must file earlier.


Clark is a member of O’Melveny’s Investment Funds and Securitization Practice and resides in the Firm’s New York office.