From the category archives:

CPO

CPO Quarterly Filing Reminder

May 11, 2010

NFA Rule 2-46 Filing Due Monday May 17th NFA Rule 2-46 requires most registered CPOs to submit certain information to the NFA on a quarterly basis.  The filing is due within 45 days of the end of each quarter.  The filing date for CPOs which were active in the first quarter is Monday May 17th. [...]

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CPO Annual Financial Report Filing

February 16, 2010

Information on Filing Annual Report with NFA Commodity Pool Operators (“CPOs”) are required to distribute an Annual Report, certified by an independent public accountant, to each participant in each pool it operates (i.e. the investors in the commodity/futures hedge fund) within 90 days after the pool’s fiscal year-end (normally December 31).  CPOs are also required under [...]

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Recent Issues with NFA Annual Questionnaire

February 12, 2010

As we discussed in an earlier post on NFA Annual Questionnaire, NFA Member Firms are required to complete the questionnaire on an annual basis.  The information helps the NFA in a variety of ways and the NFA encourages members to update their questionnaire on a regular basis, although firms are only required to complete it, at [...]

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NFA Self-Examination Checklist 2010 | FCMs, IBs, CPOs and CTAs

February 8, 2010

Easy Step by Step Guide for NFA Member Firms NFA Member Firms are all required to complete a yearly self-examination checklist to ensure that the Member Firm is complying with all the NFA Rules (as well as the CFTC Regulations and other applicable laws).  The NFA has provided some resources on their website.  We believe [...]

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CFTC Provides Annual Guidance to CPOs

January 28, 2010

Annual Report Guidance for Commodity Pool Operators In a recent release, which we have reprinted in full below, the CFTC reminds CPOs of their annual reporting requirements under Regulation 4.22.  The release includes a link to the 2010 CPO Annual Guidance Letter.  In general the letter provides another reminder to CPOs to file their annual [...]

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CTA and CPO Foreign Language Disclosure Documents

January 20, 2010

Translating a Disclosure Document to Another Language is Fine NFA Member Firms are required to have their disclosure documents reviewed by the NFA generally before such firms can distribute the documents to potential investors.  One issue which sometimes arises is when the firm (generally either a CTA or CPO) has potential clients/investors who are non-U.S. [...]

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Eligible Contract Participant (ECP) Definition

January 15, 2010

The term “eligible contract participant” is important with regard to managers who provide advice on futures and commodities investments (including off-exchange spot foreign currency or “forex”).  In general there are exemptions from various CTA, CPO and IB registration provisions for those managers who only provide advisory services to those clients who fall within the definition [...]

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NFA Provides Social Networking Compliance Guidance

January 12, 2010

Member Firms Subject to Increased Oversight & Compliance Responsibilities In early December the National Futures Association (“NFA”) submitted two proposed amendments proposed amendments to the Commodity Futures Trading Commission (“CFTC”) regarding NFA Member Firms and their use of the internet and social media networks.  The amendments focus on communications by firms over the internet in [...]

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NFA Annual Questionnaire

January 11, 2010

Reminder to NFA Member Firms As part of the annual processes and procedures NFA Members will need to make sure that they complete the NFA Annual Questionnaire.  As discussed below in the NFA’s most recent notice to members, it is important that NFA Members complete the questionnaire because some of the answers will appear as [...]

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Qualified Eligible Person (QEP) Definition

December 24, 2009

The securities laws can be written obtusely and the definition of a qualified eligible person (QEP) may be one of the best examples of this.  There is no quick and easy definition of a what a QEP is so we are trying to make it as easy as possible to understand.  This post discusses the [...]

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