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January 10, 2005
NFA launches an electronic system for filing pool financial statements
National Futures Association ("NFA") is pleased to announce that EasyFile, a Web-based electronic system for filing financial statements, is now available to allow Commodity Pool Operators ("CPOs") to file their annual pool financial statements ("PFS") electronically with NFA.
Participation in this program is voluntary, but we are confident that you will find EasyFile to be a more efficient and cost-effective way for you to meet your financial reporting requirements. In that regard, we would like to encourage you to participate in our pilot program by using EasyFile to submit your December 31, 2004 pool financial statements. Using EasyFile means that you will only have to submit your PFS electronically to NFA - you will not need to file a hard copy of the statement with NFA or the CFTC.
EasyFile for CPOs involves a 3-step process:
1. Uploading a PDF of the identical PFS provided to the pool's limited partners, including the various financial statements, footnotes, Schedule of Investments and the Independent Auditors Opinion, if applicable;
2. Entering key financial balances into a standardized schedule; and
3. Validating the submission to process some basic edit checks by the system and prompt the submitter to read and agree to an electronic oath or affirmation. This electronic oath or affirmation will serve as the CPO's oath if the firm does not include such oath in its PDF file and will cover both the information included in the PDF file and the financial data entered into the schedule of key financial balances.
User Set-up and Security
To set up EasyFile initially, the security manager for your firm will need to assign system security through NFA's Online Registration System. (If you have any questions regarding who is your firm's security manager, please contact NFA's Information Center at (800) 621-3570, and an NFA representative will assist you.) If you are already an ORS user, your security manager will give you a security level for EasyFile by:
1. Signing on to ORS;
2. Clicking on the 'Security' tab;
3. Clicking on the 'Display Users' link;
4. Clicking on the 'Edit account' icon for the user that should have EasyFile access;
5. Scrolling down and updating the Security level for the EasyFile System from 'None' to either 'Enter' or 'Enter and Submit.'
The 'Enter' Security level allows you to enter the financial information into the system only. The 'Enter and Submit' Security level allows you to enter the financial information and submit the statement. The submission capability is the electronic equivalent of manually signing the oath or affirmation that, to the best knowledge and belief of the individual making such oath or affirmation, the information contained in the document is accurate and complete. Therefore, your security manager should assign the 'Enter and Submit' security level only to persons who are representatives duly authorized to bind the pool operator.
If you do not have access to ORS, your security manager has the ability to add you as an additional user by:
1. Signing on to ORS;
2. Clicking on the 'Security' tab;
3. Clicking on the 'Add Firm User' link;
4. Entering all required information for the new user; and
5. Designating the security level for the user as either 'Enter' or 'Enter and Submit; and
6. Clicking on the 'Add' button at the bottom of the page.
The system will generate a User ID and password for you as the new user. You will be able to sign on and access the EasyFile system after approximately 15 minutes. In addition, the first time you access ORS as a new user, the system will prompt you to change your password for security purposes.
Once you have set up security, you are ready to use EasyFile. Access to EasyFile is available on NFA's Web site, www.nfa.futures.org. Under the Compliance heading on NFA's Home page, go to the Electronic Filings drop-down menu and select EasyFile (Pool Filers). After you enter your User ID and password, the system will list all the pools for your CPO. Once you select a pool name, the 'Filing Index' will be displayed with the various options available regarding that particular pool's financial statements. We are providing system help and a line item help function for each balance within EasyFile to assist you with your filings.
For CPOs that voluntarily participate in the EasyFile pilot program and submit their PFS electronically, the CFTC has provided relief from the requirement to file a manually signed PFS with NFA as outlined in CFTC Regulation 4.22(h). Therefore, as stated earlier, using EasyFile means that you only have to submit your PFS electronically to NFA and do not need to file a hard copy of the statement with NFA or the CFTC. Please note that CFTC recordkeeping regulations require that you maintain on file a manually signed PFS and any reconciliation or record showing where the balances entered onto the schedule of key financial balances appear on the PDF statement.
We hope that you will find the EasyFile system beneficial and easy to use. We would welcome any comments or feedback you have about the system.
If you have any questions regarding EasyFile, please contact Patricia Cushing or Lisa Marlow at (800) 621-3570. You may contact Ms. Cushing directly by telephone at (312) 658-6747 or e-mail at firstname.lastname@example.org. You may contact Ms. Marlow directly by telephone at (312) 658-6525 or e-mail at email@example.com.