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On February 8, the National Futures Association (NFA) released three Notices to Member that cover educational resources, common regulatory and compliance deficiencies, and recent amendments to NFA Rules and Interpretative notices, each aimed at a different audience, as indicated below.
Continue Reading NFA Publishes Series of Member Notices Related to Common Deficiencies and Other Regulatory Matters

On July 8, the National Futures Association (NFA) issued Notice I-20-27 to remind member firms that the compliance date for NFA’s Swaps Proficiency Requirements (Requirements) is January 31, 2021 (Compliance Date). NFA Members with associated persons (AP) required to satisfy the Requirements must ensure that covered individuals are in compliance by the Compliance Date. Individuals who do not satisfy the Requirements by the Compliance Date will be unable to engage in swaps activities until they have done so.
Continue Reading NFA Issues Notice to Members Regarding Compliance Date for Swaps Proficiency Requirement

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

On April 19, the Commodity Futures Trading Commission approved a final rule revising CFTC Regulation 160.5. The amended rule implements the Fixing America’s Surface Transportation Act’s (FAST Act) December 2015 statutory amendment to the Gramm-Leach-Bliley Act (GLB Act) by providing an exception to the requirement that certain futures commission merchants, retail foreign exchange dealers, commodity trading advisors, commodity pool operators, introducing brokers, major swap participants and swap dealers (each, a “covered person”) to provide annual privacy notices to their respective customers. (The obligation to provide an initial privacy notice is unchanged).
Continue Reading CFTC Approves Final Rule Providing Exception to Annual Privacy Notice Requirements

On June 30, the National Futures Association (NFA) published Notice to Members I-17-11, establishing an electronic process for a registered commodity trading advisor (CTA) to notify the NFA where the CTA uses a third-party recordkeeper. This notice is effected through the NFA’s electronic Exemptions System by claiming a “4.7(c)(2)” or “4.33” exemption, as applicable, and…

The National Futures Association (NFA) has proposed an amendment to NFA Compliance Rule 2-46 that would add a late filing fee of $200 for each business day that NFA Form PQR or Form PR is filed after the applicable deadline. NFA Form PQR and Form PR are required to be filed with the NFA on a quarterly basis by registered Commodity Pool Operators (CPOs) or Commodity Trading Advisors, respectively. For late NFA Form PQRs, the fee will apply at the CPO level and will not be assessed separately for each pool operated by the CPO that has a late filing.
Continue Reading NFA Proposes Late Filing Fee for NFA Form PQR and Form PR