Partner Bertrand Fry, co-chair of Pryor Cashman’s Investment Management Group, and Nir E. Gozal of Pryor Cashman’s Corporate Group, have authored an important Legal Update summarizing the developments affecting the private offering marketplace.

On September 9, 2014 the staff of the Commodity Futures Trading Commission issued CFTC Letter 14-116 allowing commodity pool operators that rely on the exemptions under CFTC Rules 4.7(b) and 4.13(a)(3) to publicly market their commodity pools, subject to certain conditions. In response to the Securities Exchange Commission’s amendments to Rule 506 of Regulation D and Rule 144A, implementing the JOBS Act, the letter harmonizes the CFTC’s exemptive regime with the SEC’s private placement regime.

To read the Legal Update in its entirety, click here.