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Does a CPO always have to file a pool disclosure document with NFA?

No. A registered CPO that is required to provide a disclosure document must file it with NFA, but some pools are exempt from the requirement. For example, a disclosure document is not required for a pool that is sold solely to qualified eligible persons if it meets the requirements for an exemption under CFTC Regulation 4.7. If a disclosure document is required, it cannot be used until it is reviewed and accepted by NFA. 

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