Full and fair disclosure is at the heart of the U.S. securities laws. The CFTC and SEC recently severely penalized a commodity pool operator and one of its exchange-traded commodity futures funds for failing to disclose that the sole futures commission merchant through which the fund purchased futures contracts had greatly restricted the fund’s ability to trade futures contracts. Both regulators took issue with disclosures that indicated that the fund “could” be subject to trading restrictions when the fund was already, in fact, subject to material restrictions. This article discusses the circumstances leading to the enforcement actions and the terms of the CFTC and SEC settlement orders. See “CFTC Accuses Swaps Trader of Price Manipulation, Deceptive Conduct and Making False Statements” (Jun. 10, 2021); and our two-part review of recent CFTC activity: “Enforcement Actions” (Apr. 15, 2021); and “Regulatory Actions” (Apr. 29, 2021).