Regulatory Update for CPOs and CTAs

2019 brought significant regulatory developments for registered Commodity Pool Operators (“CPOs”) and Commodity Trading Advisors (“CTAs”). Review the below notices from 2019 as you plan your 2020 compliance program:

• A new Interpretive Notice on CPO Internal Controls
• An updated Interpretive Notice related to cybersecurity
• An updated Interpretive Notice related to branch offices
• Updates to NFA Compliance Rule 2-29 and related Interpretive Notices dealing with promotional material

There are also a couple of new requirements coming into effect for NFA/CFTC registered firms this year:

• The Swaps Proficiency Requirement, effective January 31st
• Updates to NFA Compliance Rule 2-34 and related Interpretive Notice dealing with CTA performance reporting and disclosures, effective February 1st

As you assess these new requirements, you may also be working on Bylaw 1101 due diligence, ahead of the March 2nd deadline to affirm certain exemptions.

ACA Guidance

The beginning of the new year is a great time to review your compliance program and ensure it meets the new guidance and regulatory requirements. Take time this quarter to review and update your compliance manuals, calendars, and training programs as necessary. Stay on top of key regulatory filing deadlines with this regulatory filings calendar.

How ACA Can Help

ACA’s NFA/CFTC Division is made up entirely of former regulators who are well-positioned to support you with your NFA/CFTC compliance program.

Connect with us to discuss:

• How the developments discussed above may impact your firm
• How the NFA is currently approaching these requirements in its examinations
• How to benchmark your interpretation and approach to that of your peers

To learn more, please contact Rick Geissman at 212-951-1030 x1066.