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.