Commodity Pool, NFA

Registered CPOs and CTAs Must Take Action with NFA by October 2024

Dechert LLP on 6/28/2024

Pursuant to new National Futures Association (NFA) Compliance Rule 2-52, Interpretive Notice 9082 and amendments to NFA Bylaw 301, for NFA membership filings, membership renewals and material updates made after October 15,...more

NFA Institutes New Operational Requirements for Members; Registered CPOs and CTAs Need to Take Action in Q3 and Q4 2021

Dechert LLP on 5/13/2021

The National Futures Association has adopted two new operational requirements that will affect (among others) registered commodity pool operators and commodity trading advisors. Under new NFA Compliance Rule 2-50, as of...more

CFTC Proposes Changes to Form CPO-PQR

Dechert LLP on 4/18/2020

The Commodity Futures Trading Commission published on April 14, 2020, a proposal to amend certain compliance requirements for commodity pool operators under CFTC Rule 4.27 and CFTC Form CPO-PQR, as codified at Appendix A to...more

CFTC Proposes to Narrow its CPO-PQR to Conform to the NFA Form PQR and Add LEIs

Akin Gump Strauss Hauer & Feld LLP on 4/16/2020

On April 14, 2020, the Commodity Futures Trading Commission (CFTC) proposed, among other things, to narrow and revise the scope of information that it collects from commodity pool operators (CPOs) on its Form CPO-PQR to: ...more

NFA Issues COVID-19 Alert on Business Continuity Plans, Relief for Branch Office Requirements and Reminder on Upcoming Deadline...

Vedder Price on 3/22/2020

On March 4, 2020, the National Futures Association (the “NFA”) issued a notice to its members addressing concerns surrounding the coronavirus (COVID-19). With the coronavirus’s potential to interfere with members’ regulatory...more

COVID-19: Compliance and Legal Considerations for Asset Managers

A&O Shearman on 3/20/2020

As the world responds to COVID-19, we have identified a number of compliance and legal considerations for asset managers. We summarize a select list of these in our note below....more

CFTC Finalizes Regulation Amendments: Certain Registered and Exempt CPOs and CTAs Need to Take Action

Dechert LLP on 1/9/2020

The Commodity Futures Trading Commission published in the Federal Register on December 10, 2019 several amendments to the regulatory framework applicable to certain commodity pool operators (CPOs) and commodity trading...more

CFTC and NFA Year End Regulatory Updates

Akin Gump Strauss Hauer & Feld LLP on 12/27/2019

• Effective January 1, 2020, clarifying amendments to rules regarding communications with the public and use of promotional material will go into effect. • Effective February 1, 2020, CTA will be subject to new limitations...more

NFA Amends its Information System Security Program Requirements; CFTC-Registered CPOs and CTAs Need to Take Action by April 1

Dechert LLP on 2/8/2019

The National Futures Association (NFA), the self-regulatory organization of the futures and swap trading industry, announced to its membership on January 7, 2019 that it had amended its requirements for NFA Member Information...more

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - January 2019

Dechert LLP on 1/31/2019

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

Akin Gump Strauss Hauer & Feld LLP on 1/15/2019

• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more

NFA Issues Internal Controls Guidance for Commodity Pool Operators

Morgan Lewis on 12/14/2018

The National Futures Association (NFA) recently proposed an interpretive notice that would require members that are commodity pool operators (CPOs) to adopt and implement internal controls systems designed to deter fraudulent...more

NFA Publishes New Disclosure Requirements for Virtual Currency and Virtual Currency Derivatives Trading

Dechert LLP on 8/22/2018

The National Futures Association (NFA), the U.S. self-regulatory organization of the futures and swaps trading industry, has published a new Interpretive Notice entitled “Disclosure Requirements for NFA Members Engaging in...more

NFA Announces New Virtual Currency Disclosure Requirements

Faegre Drinker Biddle & Reath LLP on 8/21/2018

The National Futures Association (NFA) issued a notice on August 9, 2018, to its members announcing that new disclosures relating to virtual currencies and virtual currency derivatives will be required of NFA members that...more

Registered CPOs and CTAs: Prepare for June 30 Changes to NFA Forms PQR and PR

Dechert LLP on 6/14/2017

Beginning with the second quarter 2017 filings, registered commodity pool operators (CPOs) and commodity trading advisors (CTAs) (collectively, Registrants) will need to report financial information regarding their own...more

CFTC Permits Unaudited Financial Statements Upon Liquidation of a Series of a Pool That is Also a Registered Investment Company

K&L Gates LLP on 2/7/2017

The Commodity Futures Trading Commission (“CFTC” or “Commission”) has provided general exemptive relief to persons registered as commodity pool operators (“CPO”) under the Commodity Exchange Act that operate commodity pools...more

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

Morgan Lewis on 9/16/2016

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

K&L Gates LLP on 9/8/2016

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

CFTC Proposal to Amend CPO Reporting Rules

Broker-Dealer Compliance + Regulation on 8/19/2016

The Commodity Futures Trading Commission (“CFTC”) on August 5, 2016, issued a proposal to amend its rules governing commodity pool annual reports, which, if adopted, would permit commodity pool operators (“CPOs”) of a pool...more

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

Foley Hoag LLP on 6/30/2016

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

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

Dechert LLP on 2/19/2016

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

NFA Adopts Cybersecurity Guidance

Dechert LLP on 11/6/2015

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 Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

Foley Hoag LLP - Security, Privacy and the... on 10/30/2015

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs...more

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

Skadden, Arps, Slate, Meagher & Flom LLP on 9/14/2015

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 Proposes Amended Interpretive Notice Regarding Loans to CPOs by Commodity Pools

Katten Muchin Rosenman LLP on 12/24/2014

On December 12, National Futures Association (NFA) submitted to the Commodity Futures Trading Commission proposed amendments to the Interpretive Notice to NFA Compliance Rule 2-45 (Prohibition of Loans by Commodity Pools to...more

Commodity Pool › National Futures Association

"My best business intelligence, in one easy email…"