Recent Compliance Guidance from the National Futures Association

30 January 2013
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  • CPOs or CTAs claiming an exemption or exclusion under CFTC Regulation 4.5, 4.13 or 4.14(a)(8) must annually affirm the applicable exemption or exclusion within 60 days of each calendar year end. The first annual affirmation is due by March 1, 2013.
  • The NFA has issued guidance to Members with respect to compliance with Bylaw 1101 in several scenarios, including with respect to dealings with previously exempt CPOs and CTAs. In addition, the NFA has (i) provided CTA Members with a reminder notice that annual Form PR reports are due by February 14, 2013 and (ii) indicated to CPO Members that operate commodity pools that are registered investment companies that they must notify the NFA of this fact by February 15, 2013.