NFA Issues New Reporting Requirements for Member CPOs and CTAs That Trade Virtual Currency Products

By: William J. Breslin, Darren A. Littlejohn, Robert M. McLaughlin, David S. Mitchell, Scott I. Golden, Victoria T. Mazgalev, Matthew S. Smith 

On December 14, 2017, the National Futures Association (“NFA”) issued a Notice to Members (the “Notice”) requiring each registered commodity pool operator (“CPO”) and commodity trading advisor (“CTA”) to notify NFA immediately if it executes a transaction involving any virtual currency or virtual currency derivative on behalf of a commodity pool or managed account.  Until further notice, this obligation will apply on a continuous basis—any CPO or CTA that does not currently trade virtual currencies or related derivatives must notify NFA if it begins trading these products.

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