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.
- 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.
- 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
- 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.
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.