Notices to Members

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Notice I-04-06

February 06, 2004

Annual Regulatory Reminder for Commodity Trading Advisors

National Futures Association has always been committed to providing our Members with the resources they need to meet their regulatory obligations as efficiently as possible. During some of our recent audits, NFA Members have suggested that we provide them with an annual reminder regarding certain requirements that are not part of their day-to-day operations. Responding to this request, NFA is pleased to send you this email listing certain requirements you have for the upcoming year. This list does not capture all of your responsibilities, but it should help remind you of certain non-routine requirements.

Within the next 12 months you will be required to:

    1. Complete the Annual Update/Questionnaire on NFA's website and pay your NFA dues on the anniversary date of your firm's registration.

    2. Complete NFA's Self-Examination Checklist.

    3. Send your firm's Privacy Policy to every current client (in addition to sending it to every new client when the client enters into an advisory agreement or purchases a subscription).

    4. Test your Disaster Recovery Plan and make any necessary adjustments.

    5. Provide Ethics Training as outlined in your firm's written Ethics Training Procedures.

    6. If soliciting new clients, distribute a Disclosure Document that is no more than 9 months old and that has been reviewed by NFA.

    7. If placing bunched orders, analyze each trading program at least quarterly to ensure that the order allocation method has been fair and equitable and document this analysis.

We recommend that you keep this email as a reference guide to ensure that all requirements are completed on time throughout the year. As always, if you need assistance with these or any other NFA requirements, please contact NFA's Information Center at (800) 621-3570.

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