Housekeeping, Reminders and Updates – April 2017

 Written by:    Mark E. Ruddy, Esq. Jessica I. Brown, CAMS FINANCIAL CRIMES ENFORCEMENT NETWORK Update to FATF List of Jurisdictions with AML/CFT Deficiencies On April 5, 2017, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory announcing that the Financial Action Task Force (“FATF”) updated its lists of identified jurisdictions with strategic deficiencies in their frameworks to combat money laundering…

Housekeeping, Reminders & Updates February 2017

NATIONAL FUTURES ASSOCIATION December 31, 2016 NFA Form PQR The National Futures Association (“NFA”) emailed a reminder to commodity pool operators (“CPOs”) regarding quarterly reports and possible late fees. The 2016 fourth quarter CPO quarterly report (“Form PQR”) is due in March. CPOs that have more than $1.5 billion in assets under management (“AUM”) are required to file Form PQR…

Housekeeping, Reminders & Updates – January 2017

Financial Crimes Enforcement Network Advisory on FATF List of Jurisdiction with AML/CFT Deficiencies On January 19, 2017, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory announcing that the Financial Action Task Force (“FATF”) updated its lists of identified jurisdictions with strategic deficiencies in their frameworks to combat money laundering and the financing of terrorism and proliferation.  The purposes of…

December 2016 Housekeeping, Reminders and Updates

COMMODITY FUTURES TRADING COMMISSION Inter-Affiliate Swaps Transactions No-Action Extension The Commodity Futures Trading Commission (“CFTC”) announced the extension of relief outlined in Letter 15-62 and Letter 16-81 until December 31, 2017. Non-U.S. jurisdictions are still constructing mandatory clearing regimes. The no-action relief extension allows for market participants to more easily satisfy clearing and trade execution requirements while foreign jurisdictions implement…

Housekeeping, Reminders and Updates–November 2016

COMMODITY FUTURES TRADING COMMISSION Filing Period for CCO Annual Reports Extension The Commodity Futures Trading Commission (“CFTC”) announced the unanimous approval to modify CFTC Regulation 3.3. Until now, Regulation 3.3 mandated electronic filings to be completed no more than sixty (60) days after the registrant’s fiscal year-end. The modification changes registrants’ (futures commission merchants, swap dealers and major swap participants)…

Housekeeping, Reminders and Updates October 2016

  COMMODITY FUTURES TRADING COMMISSION Swap Dealer Registration De Minimis Exception In a press release issued October 13, 2016 (Release: PR7471-16) the Commodity Futures Trading Commission (“CFTC”) announced the approval of an order establishing de minimis threshold phase-in termination date pursuant to CFTC Regulation 1.3(ggg)(4)(ii)(C)(1), (the “Order”). The Order delays the de minimis threshold phase-in termination date by one year. …

Housekeeping, Reminders and Updates — September 2016

Financial Crimes Enforcement Network Advisory on FATF List of Jurisdiction with AML/CFT Deficiencies On September 7, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory announcing that the Financial Action Task Force (“FATF”) updated its lists of identified jurisdictions with strategic deficiencies in their frameworks to combat money laundering and the financing of terrorism and proliferation. The purpose of…

Housekeeping, Reminders, and Updates

Mark E. Ruddy, Esq. and Elizabeth A. Cannon August 24, 2016 NATIONAL FUTURES ASSOCIATION   NFA Updates Self-Examination Questionnaire for FCMs, FDMs, IBs, CPOs and CTAs   On August 15, 2016, the National Futures Association (“NFA”) announced updates to its Self-Examination Questionnaire. On an annual basis, NFA member futures commission merchants (“FCMs”), forex dealer members (“FDMs”), introducing brokers (“IBs”), commodity…

Housekeeping, Reminders and Updates

Late Fee for CTA and CPO Quarterly Reports On June 21, 2016, the National Futures Association (“NFA”) announced an amendment to NFA Compliance Rule 2-46 (“Rule 2-46”), which will a impose late fee for commodity trading advisors (“CTAs”) and commodity pool operators (“CPOs”) quarterly reports filed after the due date. Form PQR is the quarterly report for CPOs and Form…

HOUSEKEEPING, REMINDERS AND UPDATES

NATIONAL FUTURES ASSOCIATION CPO and CTA Quarterly Reporting Requirements for Period Ending March 31, 2016 Each commodity pool operator (“CPO”) Member and commodity trading advisor (“CTA”) Member with reporting requirements under Commodity Futures Trading Commission (“CFTC”) Regulation 4.27 is required to comply with National Futures Association (“NFA”) quarterly reporting requirements. NFA Compliance Rule 2-46 imposes quarterly reporting requirements on CPOs…