Sponsors (2)
The bill reduces registration and legal uncertainty for certain nonprofits, small advisers, and SEC-registered firms but tightens and narrows exemptions in ways that could push some organizations back into CFTC regulation, raise compliance costs, and expose volunteers to enforcement risk.
Nonprofit charities and their trustees/officers/employees/volunteers can run commodity trading/pooled-vehicle advisory activities for qualifying charities without CFTC registration, reducing regulatory and compliance burdens for many nonprofits.
Very small commodity trading advisers advising 15 or fewer persons keep an exemption, preserving lower regulatory costs for small advisors and small-business owners.
SEC-registered investment advisers that do not primarily act as commodity trading advisers retain an exemption, avoiding duplicative registration and compliance for many financial firms.
Charities and small advisors that no longer meet the narrower exemptions may be forced back under CFTC registration, increasing compliance costs and operational burdens for many organizations.
Limiting charitable exemptions to activities performed only on behalf of qualifying charities could restrict charities' ability to advise or pool resources with outsiders, narrowing fundraising and investment options for some nonprofits.
Individuals (including volunteers and small nonprofit staff) who claim incidental or charitable exemptions would still be subject to enforcement proceedings under section 14, exposing them to regulatory risk and potential legal consequences.
Based on analysis of 2 sections of legislative text.
Adds a limited CTA/CPO exemption for qualifying charitable organizations and related persons, narrows its scope to charity-focused activity, and requires Investment Company Act–style disclosures.
Official title: To exempt charitable organizations from commodity trading regulations and registration requirements.
Introduced December 11, 2025 by April McClain Delaney · Last progress December 11, 2025
Amends the Commodity Exchange Act prohibition on unregistered commodity trading advisors (CTAs) and commodity pool operators (CPOs) to clarify exceptions and explicitly add an exemption for certain charitable organizations and related persons. The change limits the exemption so those advisors/operators may act only on behalf of qualifying charities or similarly excluded entities and requires specified disclosures modeled on the Investment Company Act.