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Like FCMs and independent IBs, CPOs are required to maintain accounting systems and prepare periodic financial statements for each pool they operate. CPOs must distribute account statements to pool participants. They also must distribute a certified Annual Report to each pool participant and to NFA each year.
NFA has received a number of requests from CPO Members for information on how to request confidential treatment of their commodity pool annual reports that are filed with NFA. Requests for confidential treatment are governed by Commodity Futures Trading Commission ("Commission") Regulation 145.9, which contains detailed requirements for submitting a request for confidential treatment of information filed with the Commission, including commodity pool annual reports.
Every registered CPO and CTA must supply prospective participants with a Disclosure Document. The document is intended to provide information customers need to make informed investment decisions. Each pool participant has to sign and return a statement that they have seen, read and understood the pool's Disclosure Document.
The regulations are specific in terms of when the Disclosure Document must be provided and what information has to be included. Disclosure Documents: A Guide for CPOs and CTAs discusses the requirements CPOs and CTAs must meet under Part 4, presents a break-even analysis and sample performance table and describes the review and approval process used by NFA's Disclosure Document Review Team.
NFA also has a Sample Performance Calculation that may be used by firms when they are calculating returns and drawdown figures in their Performance Capsule. NFA does not promote one method for determining rate of return, this spreadsheet should only be used as one tool when completing your Performance Capsule. To open the Calculation, right click on the link and save the file to your hard drive.
CPOs and CTAs may submit Disclosure Documents electronically by sending them as an attachment to ddoc@nfa.futures.org.
NFA offers excellent resources for its CPO and CTA Members. NFA conducted two CPO/CTA workshops that covered all aspects of CPO and CTA operations from registration to soliciting clients to filing financial statements and preparing for an NFA audit. The first workshop was held on October 24, 2006 in New York City. The second workshop was held on May 3, 2007 in Chicago, Illinois. In addition, CFTC Commissioner Walt Lukken gave the keynote address for both workshops. Audio recordings of all the sessions are available on CD free of charge. To request a CD, simply e-mail NFA's Information Center at information@nfa.futures.org. Be sure to note which CD you are requesting and include your mailing address.
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