Important Reminder Regarding March 1 CPO/CTA Exemption Affirmation Deadline

February 26, 2013

Pursuant to requirements adopted by the Commodity Futures Trading Commission (the “CFTC”) in 2012, all persons that: (i) claim an exemption from registration as a commodity pool operator under CFTC Regulation Section 4.5 or 4.13 or (ii) claim an exemption from registration as a commodity trading adviser under CFTC Regulation Section 4.14(a)(8), must file an affirmation of the applicable notice of exemption within 60 days of each calendar year end (March 1, 2013 for calendar year 2012) through the National Futures Association’s Exemptions System. Failure to affirm an exemption will result in such exemption’s automatic withdrawal. Exemptions filed after December 3, 2012 will not require affirmation until 2014.

For further information, please review our January 30, 2013 Memorandum to Clients regarding annual regulatory requirements. If you have any questions, or need any assistance with the foregoing, please contact your primary attorney in Seward & Kissel’s Investment Management Group.


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