InstructorTerri Hays
TypeOnline Course
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Tuition Options


PracticeEdge Elite™

Standard Tuition $400 US

Senior Fellow Matthew Eisenberg, JD, Partner, Finn Dixon & Herling

An increasing number of SEC-registered investment advisers are now managing and/or advising private funds that invest in “commodity interests,” (defined in the Commodity Exchange Act) and are therefore subject to regulation by the Commodity Futures Trading Commission (“CFTC”).

This Course will review the determination of whether or when an investment adviser is required to register as a commodity pool operator and/or a commodity trading advisor. The Course will then outline the steps involved in registering as a commodity pool operator or commodity trading advisor and becoming a member of the National Futures Association (“NFA”), and provide a broad overview of the post-registration compliance requirements under CFTC and NFA rules and regulations, including some specific differences from investment adviser compliance obligations.


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Students shall learn the following within this Course:

  • Define a “commodity interest”;
  • Differentiate between a Commodity Pool Operator and a Commodity Trading Advisor;
  • Determine whether commodity pool operator and/or a commodity trading advisor registration is required;
  • List the commonly relied upon exemptions from commodity pool operator and commodity trading advisor registration;
  • Identify the steps required to register as a commodity pool operator and rely on CFTC Rule 4.7;
  • Determine the investment adviser’s “associated persons” and “principals”;
  • Develop relevant compliance procedures to supplement the firm’s existing compliance program; and
  • Identify regulatory “trouble spots” focused on by the CFTC and/or NFA.

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Senior Fellow:

Matthew Eisenberg, JD, Partner, Finn Dixon & Herling

Guest Lecturers:
Patricia Cushing, CPA, Director – Compliance, NFA
Tracey Hunt, CPA, CFE, Associate Director – Compliance, NFA
Michael Sheehy, Senior Vice President & Chief Compliance Officer, CoreCommodiity Management
Justin Shigemi, JD, Senior Associate, Finn Dixon & Herling
Richard Kilbride, JD, Counsel, Finn Dixon & Herling


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Accreditation Information

CLE Information

Credit Hours: 4
Subject Area: Professional Practice
States: Contact Curriculum Advisor For More Information

CPE Information

Credit Hours: 6
Subject Area: Accounting
States: Contact Curriculum Advisor For More Information


Course ID Number:  8090


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Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits.

Arizona: Does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. RCA programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.

Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts.

Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit.

New Hamphsire: The approval is for three years from recorded date.

New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year.

New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web Programs or live Webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.

North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs.

Ohio: To confirm that the web program has been approved, please refer to the list of Ohio’s Approved Self Study Activities at Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.

Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs.

Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour.

Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component.

Tennessee: The approval is for the calendar year in which the live program was presented.

Virginia: All distance learning courses are to be done in an educational setting, free from distractions.

Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts.

Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

If applicable, the RCA will apply for credit in your state upon request.