The new policy (Policy) announced by the CFTC’s Division of Enforcement on May 19, 2026, is designed to incentivize self-reporting and cooperation and to establish a clear path toward declination. However, more guidance is needed to alleviate doubts as to the ultimate benefits of self-reporting, according to legal experts interviewed by the Hedge Fund Law Report. In the absence of further clarity, parties should not automatically rush to self-report when they become aware of violations or assume they can easily secure a declination. This second article in our two-part series compares the Policy to the superseded February 2025 Enforcement Advisory and to other agencies’ cooperation policies; assesses its potential impact; and provides practical takeaways. The first article summarized the Policy and its cooperation safe harbors. See our two-part series “Why, When and How Fund Managers Should Self-Report Violations to the SEC”: Part One (Jan. 10, 2019); and Part Two (Jan. 17, 2019).