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April 03, 1996
NFA Expands CPO/CTA Regulatory Information
Helping our Members comply with rules and regulations has always been a goal of NFA's educational programs. In keeping with that goal, we have enclosed in this package three new publications to aid CPO and CTA Members.
This guide has been substantially revised to reflect the extensive changes to the CFTC Part 4 Regulations enacted last year and amendments to NFA Compliance Rules. The major change in the guide from previous editions is the use of "sample" Disclosure Documents to more effectively present the new requirements in this area, especially the capsule format for past performance information.
NFA's Board of Directors has interpreted Compliance Rule 2-9: Supervision to require that all Members conduct an annual review of their operations using a Self-Examination Checklist (formerly the Self-Examination Questionnaire). NFA previously mailed a separate questionnaire for each category of membership to Members on an annual basis. Some Members received as many as three questionnaires.
The Checklist included in this package incorporates all of the previous checklists into one permanent booklet. Members should keep this booklet on file in order to perform their annual review of operations. A signed and dated attestation that the review has been performed must be completed each year. A sample attestation is included in the Checklist booklet.
NFA will remind Members periodically of the requirement to perform the annual review of operations.
These step-by-step reference guides to the Disclosure Document requirements used to be included in the Self-Examination Questionnaire. They are now available as a separate pamphlet which may be used in conjunction with the regulatory guide.
We hope that these new booklets will be useful to our Members. If you have questions about any of the material, please contact the Compliance Department at (312) 781-1342. If you would like additional copies, contact the Information Center at (312) 781-1410.