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January 15, 2009
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. Therefore, we are providing you with an annual reminder regarding certain requirements that are not part of your day-to-day operations. This list does not capture all of your responsibilities for the upcoming year, 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 process on the anniversary date of your firm's registration. This process includes (1) completing the electronic Annual Registration Update; (2) electronically submitting the firm's Annual Questionnaire on NFA's Web site and (3) paying your annual registration fees and NFA dues.
Failure to satisfy all of the requirements in the annual update process within 30 days of your anniversary date will result in the withdrawal of your firm's NFA registration and/or Membership. Carefully check your registration record including address, contact information, and listed principals. Ensure any individual in a line of supervisory authority over Associated Persons ("APs") is also registered as an AP. For additional information on who has to register as an AP, see NFA's Notice to Members I-07-38 at http://www.nfa.futures.org/news/newsNotice.asp?ArticleID=1963.
2. Complete NFA's Self-Examination Checklist located on NFA's Web site at http://www.nfa.futures.org/compliance/selfexam.asp.
4. Test your Disaster Recovery Plan and make any necessary adjustments. For guidance in preparing your plan, please consult NFA's Business Continuity and Disaster Recovery Plan questionnaire (Appendix B of the Self-Exam Checklist).
5. Provide Ethics Training as outlined in your firm's written Ethics Training Procedures. For guidance in developing your procedure, please consult NFA's Ethics Training Policy questionnaire (Appendix C of the Self-Exam Checklist).
6. File any new exemption notices electronically through NFA's EasyFile system. 7. If soliciting new clients, distribute a Disclosure Document that is no more than 9 months old and that has been reviewed by NFA. CTAs trading forex transactions as described in NFA Bylaw 1507(b)(2) must prepare a Disclosure Document in accordance with NFA Compliance Rule 2-41 adopted on November 30, 2008.
8. 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.