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…...

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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…...

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Housekeeping, Reminders and Updates

Financial Crimes Enforcement Network  The Financial Action Task Force (“FATF”) updated its list of jurisdictions with strategic anti-money laundering (“AML”) and counter-terrorist financing (“CFT”) deficiencies. In response, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory in January announcing the updates to the list of jurisdictions identified as having strategic deficiencies in their AML/CFT regimes. Countries with inadequate AML/CFT programs,…...

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Housekeeping, Reminders and Updates

NATIONAL FUTURES ASSOCIATION 2015 Annual Pool Financial Statement Requirements The National Futures Association (“NFA”) has distributed reminder notices regarding filing requirements under Commodity Futures Trading Commission (“CFTC”) Regulations 4.7, 4.12 and 4.22 (“Annual Report Notice”) to Registered commodity pool operators (“CPOs”). Pursuant to CFTC Regulations, CPOs are required to distribute a certified audit (“Annual Report”) to investors within ninety (90)…...

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Housekeeping, Reminders, and Updates December 2015

COMMODITY FUTURES TRADING COMMISSION  Extension of Time-Limited No-Action Relief from Certain Recordkeeping Requirements  On December 8th, the Commodity Futures Trading Commission (“CFTC”) issued a press release regarding the no-action letter issued by the Pision of Swap Dealer and Intermediary Oversight and Pision of Market Oversight (Press Release: PR729-15) . The no-action letter extended the relief relating to records of oral…...

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HOUSEKEEPING, REMINDERS AND UPDATES NOVEMBER 2015

COMMODITY FUTURES TRADING COMMISSION Form CPO-PQR and FORM CTA-PR Frequently Asked Questions On November 5, 2015, the Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealers and Intermediary Oversight (“DSIO”) published a Frequently Asked Questions (“FAQs”) regarding Form CPO-PQR (“Form PQR”) and Form CTA-PR (“Form PR”). Generally, the Form PQR is a quarterly report filed by commodity pool operators (“CPOs”)…...

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NFA Announces 2015 Nominations

NFA’s Articles of Incorporation were amended to reduce the size of NFA’s Board of Directors from 37 to 29 Directors. The new Board structure will be in place in February 2016, and all current Directors’ terms expire at the Board’s regular Annual Meeting on February 18, 2016. In accordance with NFA Bylaw 406, the Office of the Secretary has received…...

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Housekeeping, Reminders and Updates

NATIONAL FUTURES ASSOCIATION Information Systems Security Programs – Cybersecurity On October 23rd the National Futures Association (“NFA”) announced the adoption of the interpretive notice regarding NFA Compliance Rules 2-9, 2-36 and 2-49. The purpose of the interpretive notice was to address information systems security programs – cybersecurity. The interpretive notice entitled Information Systems Security Programs (“Cybersecurity Interpretive Notice”) was recently…...

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Chairman’s Letter

Dear Members: Lately I’ve been reading a lot about the “vanishing FCM.” In the July issue of our newsletter, Marc Nagel wrote an excellent article on the subject. And Ginger Szala wrote an equally thoughtful piece for CTA Intelligence a few months ago. NFA records list 62 FCMs registered in late July of this year. Contrast that number with 189…...

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Housekeeping, Reminders, and Updates

Financial Industry Regulatory Authority Redesigned FINRA Website In March, the Financial Industry Regulatory Authority (“FINRA”) announced the launch of its newly redesigned website. Two key factors were the driving force behind the updates to the website: improve the user-experience of BrokerCheck and creating a more mobile-friendly interface to address the increase traffic to the website from mobile devices. The launch…...

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