Effective April 1, 2019 all Commodity Pool Operators having the ability to control customer funds must adopt and implement an internal controls framework. The internal controls must be designed to protect customer funds, provide reasonable assurance that the books and…
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CPO and CTA Affirmation Deadline Approaching
If you are a CTA and CPO and you currently claim an exemption under 4.13(a)(2), (a)(3), (a)(5), or exclusion from CPO registration under CFTC Reg 4.5 or CTA registration under 4.14(a)(8), you must reaffirm this exemption on or before March…
SEC and FINRA: RIAs and Broker Dealer Updates
By Any Other Name: Those registered investment advisors who thought the Fiduciary Rule was dead should think again. The Department of Labor’s so-called Fiduciary Rule having died earlier this year is making a comeback in a different version. But more…
NFA: Virtual Currency Activities Disclosure for IIBs, FCMs, CPOs, and CTAs
Virtual Currency Rules: In October, the NFA adopted an Interpretive Notice entitled Disclosure Requirements for NFA Members Engaging in Virtual Currency Activities. The Interpretive Notice establishes disclosure requirements for FCM, IBs, CPOs and CTAs that engage in activities related to virtual currencies…