Christian B. Hennion

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On June 22, National Futures Association (NFA) issued Notice I-20-26 announcing that the recent amendments made to Part 3 of its Compliance Rules will become effective on August 31, 2020. NFA Compliance Rule 3-14 was amended to allow an NFA disciplinary panel to impose a monetary penalty of up to $500,000 per rule violation at…

At its open meeting on June 4, the Commodity Futures Trading Commission (CFTC) unanimously approved a final rule prohibiting persons from seeking to claim a Commodity Pool Operator registration exemption under CFTC Rule 4.13 who are, or whose principals are, subject to any of the statutory disqualifications listed in Section 8a(2) of the Commodity Exchange Act (CEA).
Continue Reading CFTC Unanimously Approves Final Rule Regarding CPO Registration Exemption

In response to the COVID-19 pandemic, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief to commodity pool operators (CPOs) extending the upcoming filing deadlines for required pool quarterly reports on CFTC Form CPO-PQR, as well as annual reports and periodic account statements provided to pool participants. National Futures Association (NFA) also issued similar relief to CPOs for pool quarterly reporting requirements on NFA Form PQR and to commodity trading advisors (CTAs) for quarterly filings on NFA Form PR.
Continue Reading Regulatory Relief Issued for CPOs and CTAs

The Commodity Futures Trading Commission’s (CFTC) Energy and Environmental Markets Advisory Committee (EEMAC) announced that it will hold a public meeting at 9:30 a.m. on March 24 at the CFTC’s headquarters in Washington, DC. At the meeting, the EEMAC will consider the CFTC’s proposed rule regarding the establishment of position limits for derivatives contracts that provide for physical delivery.
Continue Reading CFTC’s Energy and Environmental Markets Advisory Committee to Meet on March 24

On March 5, the National Futures Association (NFA) submitted to the Commodity Futures Trading Commission (CFTC) proposed amendments to Compliance Rule 2-29 and Interpretive Notice 9003 regarding communications with the public and promotional material.
Continue Reading NFA Proposes Amendments to Compliance Rule 2-29 and Related Interpretive Notice

On March 12, the National Futures Association (NFA) issued Notice I-20-11, reminding swap dealer (SD) Members of their regulatory obligations, specifically with respect to Commodity Futures Trading Commission (CFTC) Regulation 23.603 regarding business continuity and disaster recovery plans. In accordance with such regulatory obligations, the CFTC expects to be notified if a SD implements a…

On February 10, the National Futures Association (NFA) issued a series of Notices to Members containing an overview of the educational resources available to Members in different registration categories to assist them in meeting their regulatory obligations, identifying common deficiencies noted during NFA examinations and providing links to other Notices regarding recent amendments to NFA Rules and Interpretive Notices applicable to certain Members.
Continue Reading NFA Provides Information to Assist Members in Meeting Their Regulatory Obligations

On December 3, the National Futures Association (NFA) proposed amendments to various NFA Compliance Rules and Interpretive Notices related to discretionary customer accounts, customer information, risk disclosures and bunched orders to apply to cleared swaps, in addition to other minor amendments. Most notably, NFA proposal would amend the following:
Continue Reading NFA Proposes Amendments to Several NFA Rules and Interpretative Notices to Apply to Cleared Swaps