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.



  • 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

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.

Testing and Training