CPO Internal Controls

NFA's Interpretive Notice entitled NFA Compliance Rule 2-9: CPO Internal Controls System requires commodity pool operator (CPO) Members, which have the ability to control customer funds, to implement an internal controls framework designed to:

  • Protect customer funds; and
  • Provide reasonable assurance that the books and records of a CPO's commodity pools are accurate and reliable and that the CPO is in compliance with all CFTC and NFA requirements.

The Interpretive Notice adopts a principles-based approach to allow these firms some degree of flexibility in determining how to implement an internal controls framework, given differences in the size of each firm and the complexity of their operations. However, the Interpretive Notice does require each CPO Member to adopt and enforce an internal controls framework appropriate to its circumstances.

To assist CPO Members in developing, implementing and maintaining their internal controls frameworks, NFA has added questions to the CPO section of its Self-Examination Questionnaire.