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NFA Announces Effective Dates for New Requirements for Member Firms

Client memorandum | May 25, 2021

The National Futures Association (“NFA”) recently issued two notices to its members that establish effective dates for new regulatory and operational requirements which apply to registered commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”).
On April 13, 2021, NFA issued Notice I-21-15, which establishes June 30, 2021 as the effective date by which member CPOs, including those operating exempt pools, must begin to notify NFA when certain market or other events affect the ability of a pool to fulfill its obligations to pool participants or which may result in a pool’s unplanned liquidation, pursuant to new NFA Compliance Rule 2-50 (the “CPO Adverse Event Reporting Requirement”).
On March 24, 2021, NFA issued Notice I-21-13, which establishes September 30, 2021 as the effective date by which members, including registered CPOs and CTAs, must have adopted and implemented a written supervisory framework that addresses key outsourcing-related risks in connection with their use of third-party service providers to fulfill their regulatory functions, pursuant to NFA Compliance Rules (“Supervision of Outsourcing Regulatory Functions”).

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