In January of this year, the NFA adopted an interpretive Notice regarding Internal Control Systems for Commodity Pool Operators (Rule 2-9)
Commodity Pool Operators (CPO) Members who have the ability to control customer funds must implement an internal controls framework that is designed to protect customer funds and provide reasonable assurance that the books and records of a CPO’s commodity pool are reliable, accurate, and in full compliance with all CFTC and NFA requirements.
Given the difference in size of each pool, some degree of flexibility to determine how to implement internal controls will be considered. However, each CPO must adopt and enforce the internal controls framework that is appropriate under their specific circumstances by April 1, 2019.
The NFA has added an appendix to its Self-Exam Questionnaire on CPO Internal Controls.
To assist with the implementation and to meet obligations, NFA will be hosting a webinar on Thursday, April 11, 2019 at 11:00 am CST/12:00 pm EST. This is free however you must register. Commodity Pools register here.
Workshop materials are also available on the NFA website.