Annual CTA Requirements
Below is a listing of certain annual requirements for commodity trading advisors (CTA). This list serves as a reminder of certain yearly requirements and does not reflect all CTA responsibilities.
Cybersecurity
- Review the CTA's written information systems security program (ISSP) using either in-house staff with appropriate knowledge or by engaging an independent third-party information security specialist.
- Provide training to employees upon hiring, at least annually thereafter, and more frequently if circumstances warrant.
Dues
- Pay NFA dues (including a $100 registration records maintenance fee for each category of registration) on the CTA's registration anniversary date.
Questionnaires and Updates
- Complete NFA's Annual Questionnaire on the CTA's membership anniversary date using NFA's Annual Questionnaire system.
- Complete the electronic Annual Registration Update in NFA's Online Registration System (ORS) when notified through NFA's Dashboard.
- Complete NFA's Self-Examination Questionnaire.
Reports and Exemptions
- Send the CTA's Privacy Policy to participants. See Appendix D of the Self-Examination Questionnaire for details.
- If soliciting new clients, distribute a Disclosure Document that is no more than 12 months from the document's date and 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. Document this analysis.
- If directing trading of commodity interests, file the annual report required by CFTC Regulation 4.27 in EasyFile (CTA Filers).
- File any new exemption notices and affirm any CTA registration exemptions electronically through NFA's Exemption system.
- The FCM that carries a CTA's customer accounts will contact the CTA's customers annually at a minimum to verify that the information obtained under NFA Compliance Rule 2-30(c) remains materially accurate, and provide the customer with an opportunity to correct and complete the information. If notified by the FCM of any material changes to the information, assess whether an additional risk disclosure is required to be provided to the customer.
Supervision
- Supervise the operations of and conduct an annual onsite inspection of every Branch Office.
Testing and Training
- Test the disaster recovery plan and make necessary adjustments.
- Provide ethics training as outlined in the CTA's written ethics training procedures.