CFTC Annual Affirmations

December 16, 2013

A commodity pool operator (“CPO”) that has filed a registration exemption under Commodity Futures Trading Commission (“CFTC”) Rule 4.13 (including Rule 4.13(a)(3)) must affirm such filing within 60 days of each calendar year end. In addition, a commodity trading advisor (“CTA”) that has filed a registration exemption under CFTC Rule 4.14(a)(8) must affirm such filing within 60 days of each calendar year end. The affirmations must be made online through the National Futures Association’s Exemption System. An exemption that is not affirmed by March 3, 2014 will be automatically withdrawn. A filing made on or after December 3, 2013 does not need to be affirmed until 2015.

If you have any questions concerning the foregoing, please contact your primary attorney in Seward & Kissel’s Investment Management Group.