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February 06, 2004
Annual Regulatory Reminder for Commodity Pool Operators
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 is pleased to send you this email listing certain requirements you have for the upcoming year. This list does not capture all of your responsibilities, but it should help remind you of certain non-routine requirements.
Within the next 12 months you will be required to:
2. Complete NFA's Self-Examination Checklist.
4. Test your Disaster Recovery Plan and make any necessary adjustments.
5. Provide Ethics Training as outlined in your firm's written Ethics Training Procedures.
6. If soliciting new pool participants, distribute a Disclosure Document that is no more than 9 months old and that has been reviewed by NFA.
7. Submit to NFA, and distribute to current participants, a certified annual report for each pool as of the close of the pool's fiscal year. If you are operating pools under an exemption, refer to the appropriate section of the Commodity Exchange Act for that pool's specific reporting requirements. When preparing pool annual reports, refer to the CFTC's annual letter for useful tips. This letter can be found at http://www.cftc.gov/tm/tmcompliance.htm.
We recommend that you keep this email as a reference guide to ensure that all requirements are completed on time throughout the year. As always, if you need assistance with these or any other NFA requirements, please contact NFA's Information Center at (800) 621-3570.