National Futures Association Commodity Trading Advisors

News & Analysis as of

NFA Proposal Would Require CFTC-Registered Asset Managers to Report on Financial Condition

The National Futures Association’s (NFA’s) latest proposal would require registered commodity pool operators and commodity trading advisors to provide new information about their financial condition in quarterly reports to...more

Recent CFTC/NFA Regulatory Actions Affecting Commodity Pool Operators and Commodity Trading Advisors

During August 2016, the Commodity Futures Trading Commission (“CFTC” or “Commission”) and National Futures Association (“NFA”) published several items that will affect commodity pool operators (“CPO”) and commodity trading...more

Late Fee for NFA Forms PQR and PR Filings Effective Starting September 30, 2016

The National Futures Association recently amended NFA Compliance Rule 2-46 in order to impose late fees for its commodity pool operator (CPO) and commodity trading adviser (CTA) members that do not make quarterly filings on...more

Reminder: March 1, 2016 Effective Date for Information Systems Security Programs Including Cybersecurity for NFA Members

As noted in our earlier Foley Adviser, March 1, 2016 is the effective date for NFA member firms (including futures commissions merchants, commodity trading advisors, commodity pool operators, introducing brokers, retail...more

CFTC Staff Issues No-Action Relief Helpful for Non-U.S. Commodity Pool Operators and Commodity Trading Advisors

The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more

Investment Management, Trading & Markets Advisory: Annual CPO or CTA Exemption or Exclusion Affirmations Due by February 29, 2016;...

Any firm that is currently claiming certain exemptions or exclusions from registration with the Commodity Futures Trading Commission (CFTC) as a commodity pool operator (CPO) or commodity trading advisor (CTA) is required to...more

Deadline Approaches for Annual CPO/CTA Exemption Filings

Firms must affirm their exemption or exclusion from CPO or CTA registration on the National Futures Association’s Exemption Filing System by February 29....more

NFA Releases Guidance for Those Operating Under an Exemption or Exclusion From CPO or CTA Registration

On December 1, the National Futures Association (NFA) released guidance pertaining to the annual affirmation requirement for persons or entities that claim an exemption or exclusion from commodity pool operator (CPO)...more

NFA Issues Notice to CPOs and CTAs Regarding EasyFile Logistics for CTA FORM PR and CPO Form PQR

The National Futures Association issued a notice explaining how Commission Forms CPO-PQR and CTA-PR can be filed through the NFA’s EasyFile System. To address member feedback on the EasyFile procedures, NFA has launched...more

Financial Services Weekly News - November 2015 #2

Regulatory Developments: CFTC and NFA Staff Publish FAQs and Other Resources for Filing and Reporting on Forms CPO-PQR and CTA-PR - On Nov. 5 the Division of Swap Dealer and Intermediary Oversight of the CFTC...more

NFA Adopts Cybersecurity Guidance

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

CFTC Requires IBs, CPOs and Certain CTAs To Be NFA Members

The CFTC has adopted a rule, Rule 170.17, requiring all registered introducing brokers (IBs), commodity pool operators (CPOs) and certain commodity trading advisors (CTAs) to become a member of a registered futures...more

"CFTC Extends Registered Futures Association Membership Requirement to Introducing Brokers, Commodity Pool Operators and Commodity...

The Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule (“Final Rule”) that formally extends the existing registered futures association (“RFA”) membership requirement to registered introducing...more

NFA Grants Form PR Reporting Relief to Certain CTAs

National Futures Association (NFA) has notified its member commodity trading advisors (CTAs) that do not direct trading of commodity interest accounts that they are no longer required to file NFA Form PR under NFA Compliance...more

Financial Services Weekly News Roundup - December 2014 #2

Editor’s Note - Spotlight on FINRA Retrospective Rule Review: On December 9, FINRA announced it had issued reports on its retrospective review of two groups of rules – a report on the rules on communications with the...more

Corporate and Financial Weekly Digest - Volume IX, Issue 47

In this issue: - SEC Sets October 2015 Target Date for Certain Dodd-Frank and JOBS Act Rulemaking - FINRA Issues Notice on TRACE Trade Reporting Obligations - NFA Issues Guidance on Exempt and Excluded...more

Corporate and Financial Weekly Digest - Volume IX, Issue 39

In this issse: - ISS Publishes Results of Annual Global Voting Policy Survey - FINRA Requests Comment on a Rule Proposal to Implement the Comprehensive Automated Risk Data System - NFA Issues Notice...more

NFA Issues Revised Forms CPO-PQR and CTA-PR

On June 5, the National Futures Association (NFA) announced the issuance of revised Forms CPO-PQR and CTA-PR. The NFA is the self-regulatory organization to which the Commodity Futures Trading Commission (CFTC) has delegated...more

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

NFA Issues Notice to Members Regarding Member Obligations Under NFA Bylaw 1101 and Compliance Rule 2-36(d)

Under Commodity Futures Trading Commission regulations, any person claiming an exemption or exclusion from commodity pool operator (CPO) or commodity trading advisor (CTA) registration pursuant to CFTC Regulations 4.5,...more

NFA Requests Comments on Need for CPO/CTA Capital Requirements

Should the National Futures Association (NFA) impose capital requirements on commodity pool operators (CPOs) and commodity trading advisors (CTAs)? On January 23, 2014, the NFA published a Notice to members seeking public...more

"NFA Requests Comments on Capital Requirements and Additional Customer Protection Measures for CPOs and CTAs"

The National Futures Association (NFA) recently issued a notice requesting comments on the advisability of subjecting registered commodity pool operators (CPOs) and registered commodity trading advisors (CTAs) to minimum...more

NFA Seeks Comment on Capital Requirements for CPOs and CTAs

National Futures Association (NFA), the industry-funded self-regulatory for the futures industry, issued a Notice to Members (Notice) on January 23, 2014, requesting comment on the concept of imposing a capital requirement on...more

Commodity Pool Operators and Commodity Trading Advisors: Are Enhanced Customer Protections on the Horizon?

On January 23, 2014, the National Futures Association (NFA) issued a Request for Comments from commodity pool operators (CPOs) and commodity trading advisors (CTAs) as to whether the NFA should adopt rules to: (1) ensure that...more

NFA Requests Comment on CPO/CTA Requirements

National Futures Association (NFA) has requested comments from its commodity pool operator (CPO) and commodity trading advisor (CTA) members on whether to adopt capital requirements to ensure that CPOs and CTAs have adequate...more

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