Commodity Pools: Reminder to Reaffirm Exemptions The CFTC requires any person that claims an exemption from Commodity Pool registration under CFTC Reg 4.13(a)(1), 4.13(a)(2), 4.13(a)(3), 4.13(a)(5), an exclusion from Commodity Pool registration under Reg 4.5 or a Commodity Trading Advisor…
CTA and CPO Compliance: Time to Reaffirm Exemptions
Any person that claims exemption from CPO registration with NFA under the following CFTC Regs: 4.13(a)(5) 4.13(a)(2) 4.13(a)(3) 4.13(a)(5) 4.5 or CTA Registration 4.14(a)(8) must reaffirm the exemption at least 60 days before calendar year end, March 1, 2022. Failure…
Branch Office Revisions for Commodity Pools, CTAs, Introducing Brokers, and FCMs
NFAs Branch Office requirements requires each CPO, CTA, FCM, RFED, and IB Member to list branch offices. Due to the COVID-19 Pandemic, the NFA provided relief from certain branch office requirements for Members that permitted their registered APs to work…
CTA and CPO Common Deficiencies
Below are a few regulatory obligations related to common deficiencies as noted during NFA audits of Commodity Pools and Commodity Trading Advisors. Cybersecurity. Commodity Pools and Commodity Trading Advisors must adopt a written Information Systems Security Program (ISSP) to address…