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October 20, 1997
NFA Assumes the Responsibility for Reviewing Disclosure Documents for CTAs and privately offered commodity pools.
Effective November 1, 1997, NFA will assume the responsibility of reviewing all disclosure documents for CTAs and privately offered commodity pools. NFA hopes that this responsibility is just one of many additional services NFA will be performing on behalf of the commodity futures industry. In order to ensure an efficient and effective review process, NFA has formed a separate team of individuals whose primary responsibility will be the review of disclosure documents.
Members must file all disclosure documents with NFA 21 days prior to the date that they intend to begin distributing the document. All documents can be submitted by mail to National Futures Association, 200 W. Madison Ave., Chicago, IL 60606, Attn: Compliance Department, or by electronic mail at email@example.com. By contacting NFA's information center at 1-800-621-3570, NFA Members will be able to obtain the name and direct extension of the individual reviewing their document.
NFA staff will strive to review all documents and provide feedback promptly. In most instances, Members can expect their documents to be accepted for filing or commented upon within 14 days. Members will receive letters of acceptance once the review process is complete. By providing acceptance letters for each disclosure document, NFA hopes that members can avoid lengthy waiting periods whenever possible. Members can also request correspondence by facsimile or electronic mail to provide maximum efficiency.
Members can continue to submit disclosure documents under the instant filing option outlined in CFTC Advisory 95-44. NFA will strive to complete this review process in 3 days. Documents qualifying for instant filing include 1) disclosure documents which do not contain material changes to previously filed documents 2) disclosure documents for new pool filings that are substantially similar to pool documents previously filed, and 3) disclosure documents filed on behalf of commodity pools operating under a CFTC Regulation 4.12(b) exemption and for pools that invest solely in other 4.12(b) exempt pools. When submitting a document for instant filing, a member should include a letter indicating which relief they are filing pursuant to, and red line any changes from documents previously accepted by NFA or commission staff.
NFA looks forward to hearing any comments that you may have with regard to how the current disclosure document review process can be improved. Our focus will be to perform an efficient review of disclosure documents, which will result in a minimum amount of disruption to our members' business practices while still ensuring appropriate disclosure is made to the investing public. Finally, Members should continue to file all pool and CTA disclosure documents with the CFTC. Disclosure documents for public commodity pools will continue to be reviewed by commission staff. Questions and suggestions can be directed to Gena Kusiak at 1-312-781-1447, Jeff Newmyer at 1-312-658-6568 or Mike Cunningham at 1-312-658-6522.