Exempt CPO Annual Affirmations and NFA Bylaw 1101 Implications for Introducing Brokers
Fund managers relying upon exemptions from registration as commodity pool operators (CPOs) pursuant to CFTC Rule 4.13(a)(1), 4.13(a)(2), 4.13(a)(3) or 4.13(a)(5) (or an exclusion in the case of CFTC Rule…