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.



  • 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

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
  • File any new exemption notices, and affirm applicable pool exemptions, electronically through through NFA's Exemption System.


  • Supervise the operations of and conduct an annual onsite inspection of every Branch Office.

Testing and Training