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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. Although no list can capture all of a Member's regulatory responsibilities, there are certain requirements that may not be part of your day-to-day operations. Below is a listing of certain requirements you have for the upcoming year. Again, 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 (including a $100 registration records maintenance fee for each category of registration) on the anniversary date of your firm's registration. See the Membership and Dues page for the current schedule of dues.
  • Complete NFA's Self-Examination Questionnaire
  • If directing trading of commodity interests, 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 12 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.

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