Part 4 of the regulations under the Commodity Exchange Act (Part 4) sets forth the compliance obligations of commodity pool operators (CPOs) and commodity trading advisors (CTAs). Regulation 4.7 exempts CPOs with pool participants that are “qualified eligible persons” (QEPs), and CTAs that advise QEPs, from certain Part 4 requirements. The CFTC recently proposed new rules that, if adopted, would impose significant new disclosure requirements for CPOs and CTAs that wish to rely on Regulation 4.7; increase the financial qualification thresholds for certain QEPs; and codify certain exemptive letter relief the CFTC routinely provides to Regulation 4.7 fund of funds pools. Comments on the proposed rules are due by December 11, 2023. This article parses the proposed rules, with commentary from Matthew Kulkin, partner at WilmerHale and former Director of the CFTC’s Division of Swap Dealer and Intermediary Oversight. See “CFTC Adopts Final Rule Revisions on CPO and CTA Exemptions and Exclusions From Compliance Obligations” (Mar. 5, 2020); and “K&L Gates Program Examines Recent CFTC Developments Affecting CPOs and CTAs” (Feb. 27, 2020).