Overview of Series 31 Exam for Managed Futures Industry In general persons who are selling futures related products are going to be required to have a Series 3 exam license.  However, some broker-dealer representatives may be able to take the Series 31 exam instead of the Series 3 exam if [...]

Ronnie Lott Keynote Speaker at CTA Conference We are gearing up for the CTA Expo in Chicago next month. The CTA Expo, which is also held in New York and London, has become the go-to event for CTAs and others member of the managed futures industry. As always, the NIBA [...]

Late Filers Possibly Subject to Disciplinary Action The NFA issued a Notice to Members on July 21, 2011 (the “Notice”) reminding commodity pool operators (“CPOs”) registered with the NFA to file their quarterly pool reports in a timely manner. Most importantly, the NFA stated that beginning with the June 30, [...]

Futures Magazine Publishes Article on Social Media by Bart Mallon In this month’s issue of Futures Magazine I wrote a featured article about the legal and regulatory issues that managers in the futures industry face with respect to the use of social media. The article, Social Media Considerations for Financial Firms, [...]

NIBA Conference / CTA Expo 2011 – New York, April 20-21 The NIBA and the CTA Expo are having their New York event this week.  Both events have a number of good sponsors and speakers and provide members of the managed futures industry with a great opportunity to network.  Bart [...]

Proposed Form CPO-PQR Released For your review, we have published the proposed Form CPO-PQR which can be found here: Form CPO-PQR As recently proposed by the CFTC, registered commodity pool operators will be required to file proposed From CPO-PQR on either a quarterly or annual basis depending on assets under [...]

As we discussed in our post on NFA annual compliance obligations, commodity pool operators will need to submit annual audited reports to the NFA by March 31 of this year.  This requirement applies generally to all CPOs unless the CPO requests exemptive relief from the annual audit requirement. The CFTC [...]

Earlier this year we provided a general overview of the annual compliance requirements for CPOs and CTAs.  The NFA has just released their annual reminder for all CFTC registratants (including IBs, FCMs and RFEDs).  The NFA notice, reprinted below in full, provides a good overview of what CFTC registered firms [...]

Proposal to Rescind 4.13(a)(3) & 4.13(a)(4) CPO Exemptions Pursuant to rulemaking required under the Dodd-Frank Act, the CFTC is jointly proposing with the SEC that CPOs and CTAs which are dually registered (that is with the CFTC and as an investment adviser with the SEC) file certain information on a [...]

CTA and CPO firms which are registered with the CFTC will need to make sure that they are completing all necessary annual compliance items in accordance with CFTC regulations and NFA rules. Below we have provided a list of the major items which registered firms should address with respect to [...]