Annual CTA Requirements

National Futures Association has always been committed to providing our Members with the resources they need to meet their regulatory obligations as efficiently as possible. During some of our recent audits, NFA Members have suggested that we provide them with an annual reminder regarding certain requirements that are not part of their day-to-day operations. Responding to this request, NFA sends an annual Notice to Members listing certain requirements you have for the upcoming year. Below are the items from this annual reminder email.  This list does not capture all of your responsibilities, but it should help remind you of certain non-routine requirements. 

• Complete an Annual Questionnaire
• Complete the electronic Annual Registration Update
• Pay your NFA dues on the anniversary date of your firm's registration
• Complete NFA's Self-Examination Questionnaire
• File the annual report required by CFTC Regulation 4.27 in NFA's EasyFile system
• Send your firm's Privacy Policy to every current participant (in addition to every new participant when the participant invests in a fund).
• On at least an annual basis, the FCM that carries your client accounts will be contacting your clients to verify that the information obtained under NFA Compliance Rule 2-30(c) remains materially accurate, and provide the client with an opportunity to correct and complete the information. If the FCM notifies you of any material changes to the information, assess whether additional risk disclosure is required to be provided to the client based on the changed information.
• Test your Disaster Recovery Plan and make any necessary adjustments.
• Provide Ethics Training as outlined in your firm's written Ethics Training Procedures
• If soliciting new clients, distribute a Disclosure Document that is no more than 9 months old and that has been accepted by NFA.
• If placing bunched orders, analyze each trading program at least quarterly to ensure that the order allocation method has been fair and equitable and document this analysis.
• File any new exemption notices electronically through NFA's Exemption system.