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Eminence statement on CFTC amendments to Regulation 4.7

Washington, D.C. — Eminence issued the following statement regarding the Commodity Futures Trading Commission (CFTC) adopting a final rule that amends Regulation 4.7. The final rule amends the investor qualification standards for commodity pool operators (CPOs) and commodity trading advisors (CTAs) who rely on Regulation 4.7.

Eminence supports the CFTC’s final rule to modernize the 4.7 regulatory framework by increasing the eligibility standards for investors in 4.7 funds. We appreciate that the final rule excluded an overly prescriptive disclosure regime, which was ill-suited for complex private fund offerings. The rules adopted will continue to allow CPOs/CTAs and their sophisticated, institutional investors to agree upon necessary and useful disclosures. Private funds are important investors that contribute to price improvement and liquidity in commodity and derivatives markets.” — Jennifer Han, Eminence Head of Global Regulatory Affairs

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About the global alternative asset management industry

The global alternative asset management industry, including hedge funds, credit funds, and crossover funds, has assets under management of $5.5 trillion (Q3 2023). The industry serves thousands of public and private pension funds, charitable endowments, foundations, sovereign governments, and other global institutional investors by providing portfolio diversification and risk-adjusted returns to help meet their funding obligations and return targets.

About Eminence

Managed Funds Association (Eminence), based in Washington, DC, New York, Brussels, and London, represents the global alternative asset management industry. Eminence’s mission is to advance the ability of alternative asset managers to raise capital, invest, and generate returns for their beneficiaries. Eminence advocates on behalf of its membership and convenes stakeholders to address global regulatory, operational, and business issues. Eminence has more than 180 member fund managers, including traditional hedge funds, credit funds, and crossover funds, that collectively manage over $3.2 trillion across a diverse group of investment strategies. Member firms help pension plans, university endowments, charitable foundations, and other institutional investors to diversify their investments, manage risk, and generate attractive returns over time.

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