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December 14, 2017
Additional reporting requirements for IBs that solicit or accept orders in virtual currency products
A number of CFTC-regulated trading venues have launched or announced plans to offer derivatives on virtual currency products, including bitcoin. Given the volatility in the underlying virtual currency products, NFA is requiring each IB to immediately notify NFA if it solicits or accepts any orders in virtual currency derivatives. Until further notice, this obligation will apply on a continuous basis—any IB that does not currently offer virtual currency derivatives must notify NFA if it begins soliciting or accepting orders in these products.
Effective immediately, an IB that solicits or accepts orders for one or more virtual currency derivatives must notify NFA by amending the firm-level section of its annual questionnaire, which is accessible by authorized users through the following link: https://www.nfa.futures.org/electronic-filing-systems/annual-questionnaire.html. The following question has been added to the firm-level section of the questionnaire:
- Does your firm solicit or accept orders involving a virtual currency derivative (e.g., a bitcoin future, option or swap)?
Beginning with the first quarter of 2018, IBs that solicit or accept orders for virtual currency derivatives will also be required to report the number of accounts they introduced that executed one or more trades in a virtual currency derivative during each calendar quarter. This information must be submitted to NFA through the firm's questionnaire no later than 15 days after the end of a quarter. NFA will issue a separate notice reminding Members of this obligation.
If you have any questions on these new requirements please contact Dale Spoljaric, Managing Director, Compliance (firstname.lastname@example.org or 312-781-7415) or Mark Kloet, Manager, Compliance (email@example.com or 312-781-7896).