Housekeeping, Reminders, and Updates

Securities and Exchange Commission Investment Advisers registered with the Securities and Exchange Commission (“SEC”) and state securities authorities are required to file an annual updating amendment to the Form ADV (“Annual Update”). Investment advisers are required to file the Annual Update by March 31st, if their fiscal year ends December 31st, so that the amendment is submitted within ninety (90) days of the fiscal year end. For investment advisers with a fiscal year end in a month other than December, the Annual Update must be filed within ninety (90) days of their fiscal year end. The Form ADV is submitted…...

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Housekeeping, Reminders and Updates

NATIONAL FUTURES ASSOCIATION Commodity Pool Operators The National Futures Association (“NFA”) has modified the EasyFile system for the annual pool financial statements submitted by commodity pool operators (“CPOs”). The NFA announced the changes to the annual pool financial statements in the February 10th Notice to Members, Notice I-15-09. Changes to the annual pool financial statements are effective for financial statements dated after November 29, 2014. EasyFile has been updated to now include a new Cover Page for each pool operated by the CPO. The pool Cover Page includes questions regarding whether the annual report is audited. Additional questions will be…...

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Housekeeping, Reminders and Updates–Jan 2015

NATIONAL FUTURES ASSOCIATION On January 15, 2015 the National Futures Association (“NFA”) released Notice to Members I-15-02 (“Notice”) regarding commodity pool operators (“CPOs”) and commodity trading advisers (“CTAs”) exempt from registration and their obligations under NFA Bylaw 1101 and Compliance Rule 2-36(d). Members operating pursuant to an exemption are required to annually affirm the applicable notice of exemption. The Notice provides details pertaining to Commodity Futures Trading Commission (“CFTC”) Regulations, which require the annual affirmation to be completed within 60 days of each calendar year end. NFA Members are required to file the affirmation notice by March 2, 2015. Failing…...

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Housekeeping, Reminders and Updates–Dec 2014

Notice I-14-33 On December 1st, the NFA released Notice to Members I-14-33 regarding the CFTC’s recent approval on the NFA’s Interpretive Notice entitled “NFA Compliance Rules 2-4 and 2-36: Prohibition on the Use of Certain Electronic Funding Mechanisms.” Effective January 31, 2015, the Interpretative Notice prohibits NFA Members from permitting customers to fund their futures and forex accounts with the use of a credit card or any other electronic method tied to a credit card. An example of another method tied to a credit card would be using payment facilitators such as PayPal that draw funds from credit card accounts. …...

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Housekeeping, reminders and updates

INTRODUCING BROKERS An October 31, 2014, Notice to Members, Notice I-14-27, announced that all introducing brokers (“IBs”) financial reports are now required to be filed electronically, this includes the annual certified reports. This is a result of the National Futures Association’s (“NFA”) amendment to Section 5 of the NFA Manual. Section 5 outlines the financial requirements for Member IBs. The amendment to the financial requirements includes the annual certified FOCUS reports, submitted by IBs that are also broker-dealers, and is effective October 31, 2014, for reports filed through the WinJammer filing system and the NFA’s EasyFile system. The WinJammer system…...

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July Housekeeping Items

Upcoming IB Filings: 1-FRs for IBs are due 7/24/2014 for the 6/30/14 filing.  That is 2 days from today (Tuesday July 22)  Please be sure to file this prior to the deadline as there is now a $1,000 per day fine for a late filing Upcoming CTA Filings: In 2013, the NFA amended Compliance Rule 2-46 to impose a quarterly reporting requirement on all CTAs. This filing requires each CTA to report general information about the CTA and its trading programs.  For CTAs who have a 6/30/2014 quarterly filing, the due date is on Thursday 8/14/2014. New CFTC Rules: CFTC…...

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Housekeeping, Reminders, and Updates

NFA Registration Update Effective June 1, 2014, NFA imposed a $1,000.00 late disclosure filing fee for members who fail to disclose or updateregistration records involving prior and/or current disciplinary matters. All disciplinary matters involving members and APs are considered properly disclosed if registrations are updated prior to NFA discovering them.  Non-disclosure of disciplinary actions will result in the $1000.00 fine. The NFA rule can be read here. CPO Reminder – Financial Statements must comply with GAAP (Generally Accepted Accounting Principles) NFA has recently been identifying and advising CPOs with regard to making sure their financial statements are in compliance with…...

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Housekeeping

CFTC Expedited No-Action Relief for CPO Delegation On May 12, 2014, the CFTC issued registration no-action relief on an expedited basis for CPOs who delegate certain activities to a registered CPO.  Under this streamlined approach, the delegating CPO must represent in its request letter that it satisfies the applicable criteria.  Such criteria includes, in part, representations that the delegating CPO: (1) has delegated to the designated CPO all of its investment management authority with respect to the commodity pool via a legally binding document, (2) does not participate in the solicitation of participants for the commodity pool, (3) does not…...

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