CFTC Charitable Organization Exemption Act of 2025

This bill exempts certain charitable organizations from commodity trading regulations and registration requirements under the Commodity Exchange Act. It amends Section 4m of the Commodity Exchange Act to add a new exemption for charitable organizations and related entities from the prohibition on using interstate commerce as unregistered commodity trading advisors or commodity pool operators.

Sec. 2, Exemption of qualified charitable organizations from regulation as commodity pool operators: This section rewrites Section 4m of the Commodity Exchange Act. It maintains the general prohibition on unregistered commodity trading advisors and commodity pool operators using interstate commerce. It then adds a new exemption for charitable organizations (as defined in the Investment Company Act of 1940) and their trustees, directors, officers, employees, or volunteers, whose advisory or pool activities are conducted only on behalf of the charitable organization or certain investment trusts excluded from the definition of 'investment company' under the Investment Company Act. It also exempts certain plans, companies, or accounts described in the Investment Company Act. The section preserves existing exemptions for dealers, farm organizations, small advisors, and SEC-registered investment advisers. Exempted charitable organizations remain subject to enforcement proceedings under Section 14 of the Commodity Exchange Act. The section also requires disclosure for exempted charitable organizations operating certain investment trusts, and clarifies that nothing in the Act relieves any person of obligations under securities laws.