News & Analysis as of

National Futures Association CPOs

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

Akin Gump Strauss Hauer & Feld LLP

CFTC Adopts Bad Actor Disqualifications for CPO Exemptions

- A CPO will be prohibited from claiming an exemption from registration under CFTC Regulation 4.13 if it or any of its principals has in their backgrounds a statutory disqualification under the Commodity Exchange Act. - A...more

Latham & Watkins LLP

A CFTC Helping Hand: DSIO Offers to Review Digital Asset Products

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Product innovation (including in pooled investment vehicles) is encouraged, but innovation must be consistent with the law. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary...more

Eversheds Sutherland (US) LLP

BDCs must reclaim relief from CPO registration

On November 25, 2019, the Commodity Futures Trading Commission (CFTC) adopted several final regulations to codify existing exemptions from commodity pool operator (CPO) registration. Among them is an exemption that was issued...more

K&L Gates LLP

CFTC and SEC Issue Privacy Guidance

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CFTC Proposes New Swap Data Reporting Requirements and NFA Proposes Dues Surcharge for Swap Firms - INTRODUCTION - The Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”)...more

K&L Gates LLP

Swaps Proficiency Requirements for Associated Persons; Revised Form 7-R

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Introduction - By a Notice to Members dated March 25, 2019, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, announced that it had amended rules and adopted an...more

Foley Hoag LLP

April 1, 2019: Effective Date of NFA Compliance Rule 2-9

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As a reminder, pursuant to an Interpretive Notice recently released by the National Futures Association (“NFA”), all commodity pool operators (“CPOs”) that are registered with the U.S. Commodity Futures Trading Commission...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

Eversheds Sutherland (US) LLP

Update to the NFA’s ISSP training, approval and notice requirements

On January 7, 2019, the National Futures Association (NFA) issued an amendment to its Interpretive Notice on required Information Systems Security Programs (ISSPs) for NFA Members. ISSPs are required by the NFA so that NFA...more

K&L Gates LLP

NFA Proposes Interpretive Notice Addressing CPO Internal Controls

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Introduction - By letter dated December 10, 2018, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, submitted to the U.S. Commodity Futures Trading Commission...more

Katten Muchin Rosenman LLP

Bridging the Week - December 2018

A federal judge said that it is not a violation of federal law for a trading firm and its chief executive officer to be smarter than their counterparties in ruling against the Commodity Futures Trading Commission in an...more

Latham & Watkins LLP

Effective October 31, 2018: New NFA Virtual Currency Disclosure Requirements

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The NFA will soon require CPO, CTA, FCM, and IB member firms to provide various disclosures warning investors of virtual currency spot and derivatives trading risks. New disclosure requirements warning customers,...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

Morgan Lewis

NFA Sets Effective Date for Disclosure Requirements in Virtual Currency Activities

Morgan Lewis on

The National Futures Association (NFA) announced the effective date of its interpretive notice that establishes virtual currency disclosure requirements applicable to futures commission merchant, introducing broker, commodity...more

Morgan Lewis

National Futures Association Issues New Virtual Currency Notification and Reporting Requirements

Morgan Lewis on

Registered futures commission merchants, introducing brokers, commodity pool operators, and commodity trading advisors should implement procedures to comply with the new requirements....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

Dechert LLP

NFA Adopts Cybersecurity Guidance

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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

Broker-Dealer Compliance + Regulation

CFTC Requires Introducing Brokers, Commodity Pool Operators, and Most Commodity Trading Advisors That Use Swaps to Become Members...

On September 14, 2015, the Commodity Futures Trading Commission (CFTC) published a final rule requiring introducing brokers (IBs), commodity pool operators (CPOs), and most commodity trading advisors (CTAs) to become members...more

Skadden, Arps, Slate, Meagher & Flom LLP

"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

K&L Gates LLP

Cybersecurity Update: National Futures Association Proposes Cybersecurity Guidance Setting Forth General Requirements for Member...

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The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more

Katten Muchin Rosenman LLP

NFA Requires Notice From CPOs that Consolidate Filings of Subsidiary Pools

National Futures Association (NFA) has issued a notice requiring all commodity pool operators (CPOs) that have filed a notice of claim under Commodity Futures Trading Commission Letter No. 14-112 to submit an additional...more

Katten Muchin Rosenman LLP

NFA Revises CPO Form PQR and CTA Form PR

The National Futures Association (NFA) has made enhancements to the CPO Form PQR and CTA Form PR (CPR) effective for the quarter ending June 30. In the PQR, commodity pool operators may no longer list themselves as...more

Katten Muchin Rosenman LLP

NFA Proposes Amendments to Its Articles of Incorporation

On May 29, the National Futures Association provided notice to its members of the unanimous approval by the NFA Board of Directors (Board) of proposed amendments to NFA’s Articles of Incorporation. Subject to approval by...more

Katten Muchin Rosenman LLP

NFA Updates BASIC to Assist With Bylaw 1101 Diligence on Delegating CPOs

The National Futures Association (NFA) has updated its Background Affiliation Status Information Center (BASIC) system to help NFA members conducting Bylaw 1101 due diligence to determine whether the commodity pool operator...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest - Volume X, Issue 14

In This Issue: - NFA Updates BASIC to Assist With Bylaw 1101 Diligence on Delegating CPOs - Second Circuit Refuses to Rehear Groundbreaking Insider Trading Case - SEC Secures Victory on Fraud Allegations...more

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