Key takeaways

• The CFTC recently proposed rule amendments on registration relief for foreign commodity pool operators ("CPOs"), commodity trading advisors ("CTAs") and introducing brokers ("IBs").
• If adopted, amended CFTC Regulation 3.10(c)(3)(i) would provide that a foreign-located person (defined as a person located outside the United States, its territories or possessions) engaged in activity that meets the definition of an IB, CTA or CPO is not required to register as such if such activity is either solely on behalf of foreign-located persons or certain international financial institutions. 
• Although the proposed amendments clarify the rationale for the relief and resolve certain concerns that we have raised previously, we believe it would be appropriate for the CFTC to provide further guidance on the meaning and scope of the term, "foreign-located person."