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June 20, 2008
Identification of Additions and Deletions in all Subsequent Versions of Disclosure Documents
CPOs and CTAs generally file with NFA subsequent versions of their original disclosure documents in three circumstances: 1) to reflect changes requested by NFA prior to acceptance; 2) to update previously accepted disclosure documents when there have been material changes to the information in the document; and 3) to update previously accepted disclosure documents at the required nine-month mark. Currently, many firms routinely submit these subsequent disclosure document filings without indicating the deletions and additions that have been made within the document from the previously submitted version. Failing to identify the additions and changes increases the risk that material issues might not be completely addressed and decreases the efficiency with which NFA is able to review and accept these filings.
In order to increase the efficiency of NFA's Disclosure Document review process, as of July 1, 2008, NFA is requiring that, in addition to submitting the revised disclosure document for acceptance, Members must also submit a copy of the document that identifies all deletions and additions from the previous version. This may be done, for example, by
striking through deletions and underlining additions. NFA will refuse to review and accept any subsequent filing that fails to include with it a copy of the document identifying the additions and deletions.
Implementation of this new procedure will allow for NFA to more efficiently focus its efforts in reviewing revised disclosure documents and expedite the review process.
If you have any questions regarding this new requirement, please contact Mary McHenry, Senior Manager, at (312) 781-1420 or Susan Koprowski, Manager, at (312)781-1288.