Annual CPO Requirements
Below is a listing of certain commodity pool operator (CPO) annual requirements. This list serves as a reminder of certain yearly requirements and does not reflect all CPO responsibilities.
Cybersecurity
- Review the CPO'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 CPO's registration anniversary date.
Questionnaires and Updates
- Complete NFA's Annual Questionnaire on the CPO'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 CPO'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 old and has been accepted by NFA.
- Submit annual pool financial statements (Annual Report) to NFA through NFA's EasyFile system, and distribute to pool participants.
- If requesting an extension to file an annual pool financial statement, file the extension prior to the due date of the filing, through EasyFile Extensions and Notice Filings.
- File any new exemption notices, and affirm applicable pool exemptions, electronically through NFA's Exemption System.
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 CPO's written ethics training procedures.