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June 29, 2021
Reminder: Effective date for NFA rules establishing CPO notice filing requirements
In April 2021, NFA issued Notice to Members I-21-15 announcing the adoption of Compliance Rule 2-50 and a related Interpretive Notice entitled Compliance Rule 2-50: CPO Notice Filing Requirements, which require commodity pool operator (CPO) Members to file notice with NFA when a market or other event affects a commodity pool's ability to fulfill its participant obligations. Compliance Rule 2-50 specifies four events that require NFA notification. The related Interpretive Notice further defines each of the notification events and provides guidance on events that do not trigger the requirement.
This rule and Interpretive Notice will become effective on June 30, 2021.
To file notice with NFA, CPOs will use EasyFile Extensions and Notice Filings, which is currently utilized to file notices for pool extension requests and fiscal year-end changes. When filing notice pursuant to Compliance Rule 2-50, firms must upload a summary of the event, as well as specify all relevant subsection(s) of Compliance Rule 2-50 and the impacted pool(s). NFA covered the CPO notice filing requirements at its recent virtual Member Regulatory Workshop. Further, step-by-step instructions for filing any type of notice are available in NFA's EasyFile Extension and Notice Filing Help guide.