News & Analysis as of

National Futures Association Commodity Trading Advisors (CTAs)

Dechert LLP

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

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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

Lowenstein Sandler LLP

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

Summaries of recent legislative and regulatory developments with respect to: •SEC’s 2022 Examination Priorities • Proposed Amendments to Form PF Requirements- •Proposed New Rules Applicable to Private Fund Advisers and...more

Dechert LLP

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

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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

Dechert LLP

CFTC and NFA Issue Relief for Registered CPOs and CTAs in Response to Disruptions Caused by COVID-19 Coronavirus Pandemic

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The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue...more

Vedder Price

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

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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

A&O Shearman

COVID-19: Compliance and Legal Considerations for Asset Managers

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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

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - February 2020

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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

Dechert LLP

SEC Proposes Rule Changes Applicable to BDCs’ Use of Derivatives and Other Transactions

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The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more

Dechert LLP

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

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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

Akin Gump Strauss Hauer & Feld LLP

CFTC and NFA Year End Regulatory Updates

• 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

Dechert LLP

New NFA Filing Obligations for Investment Advisers to BDCs Trading Commodity Interests Require Action as Soon as Practicable After...

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The Commodity Futures Trading Commission published in the Federal Register on December 10, 20191 amendments to five different aspects of the regulatory framework applicable to certain commodity pool operators (CPOs) and...more

Latham & Watkins LLP

NFA to Require Swap Proficiency Examination for Swap Associated Persons

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The NFA has implemented requirements that all swap associated persons take and pass a swap proficiency examination by January 31, 2021. Key Points: ..As of January 31, 2021, all swap associated persons will need to take...more

Akin Gump Strauss Hauer & Feld LLP

NFA to Require Swap Proficiency Testing for Associated Persons of CPOs and CTAs Who Engage in Swaps Activity

• By January 31, 2021, all swap associated persons of registered CPOs and CTAs must take and pass the NFA’s new swaps proficiency requirements. • The swaps proficiency requirements mirror the proficiency testing long...more

Dechert LLP

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

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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

Kramer Levin Naftalis & Frankel LLP

New Disclosure Rules Enhance Crypto Investor Protection

Amid concerns that many investors may not fully understand the risks associated with virtual currencies, or the limits of regulatory oversight, the National Futures Association (NFA) recently issued an interpretive notice...more

Dechert LLP

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

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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

K&L Gates LLP

CFTC and NFA Announce Changes in Regulation Regarding Position Limits and Virtual Currency

K&L Gates LLP on

Introduction - The Commodity Futures Trading Commission (“CFTC”), the U.S. federal regulatory agency for futures and other derivatives, and the National Futures Association (“NFA”), the industry-wide self-regulatory...more

Faegre Drinker Biddle & Reath LLP

NFA Announces New Virtual Currency Disclosure Requirements

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

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

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The U.S. federal securities laws and the rules of U.S. self regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

K&L Gates LLP

Virtual Currency -- NFA Reporting Requirements and CFTC Proposed Interpretation of “Actual Delivery”

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National Futures Association(NFA) is requiring that member commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) immediately notify NFA if they operate a pool or manage an account that engages in a...more

Dechert LLP

Bitcoin Futures Trading Commences; Implications for Funds and Registered CPOs and CTAs

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The Chicago Mercantile Exchange (CME) and the CBOE Futures Exchange (CFE) on December 1, 2017 self-certified contracts for bitcoin futures products with the U.S. Commodity Futures Trading Commission (CFTC). Additionally, on...more

Dechert LLP

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

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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

Goodwin

Financial Services Weekly News - December 2016

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Editor's Note - OCC to Move Forward with Federal FinTech Charter. In a development foreshadowed in the April 6, June 29 and September 14 editions of the Roundup, on December 2, the Office of the Comptroller of the...more

Morgan Lewis

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

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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

K&L Gates LLP

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

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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

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