CFTC Regulation 4.7 exempts commodity pool operators (CPOs) with pool participants that are “qualified eligible persons” (QEPs) and commodity trading advisors (CTAs) that advise QEPs from certain compliance obligations imposed by Part 4 of the regulations under the Commodity Exchange Act. In October 2023, the CFTC issued a notice of proposed rulemaking that would have imposed significant new disclosure requirements on CPOs and CTAs relying on Regulation 4.7, raised financial qualifications for certain QEPs and codified certain exemptive relief the CFTC routinely provides to Regulation 4.7 fund of funds pools. On September 12, 2024, the CFTC adopted the proposed higher QEP thresholds and codified the fund of funds exemptive relief (Rules). However, after considerable industry pushback, the CFTC decided not to impose the proposed disclosure requirements. “Relative to the proposed rule, the final rule is a win for private fund managers and their investors,” Gretchen Passe Roin, partner at WilmerHale, told the Hedge Fund Law Report. This article discusses the Rules, with additional commentary from Roin and WilmerHale partner Matthew Kulkin. See “What’s Next for the SEC and CFTC? A Look at the Latest Reg Flex Agendas” (Aug. 15, 2024); and “Evaluating the CFTC’s Actions in 2023 and the Outlook for 2024” (Jun. 20, 2024).