Our firm provides advice to commodity pool operators (CPOs) and commodity trading advisors (CTAs) in all aspects of their operations. When no exemptions from registration are available, we can help CPOs and CTAs register with the National Futures Association (NFA), prepare comprehensive NFA disclosure documents and break-even analysis, and respond to NFA personnel throughout the registration process. We also routinely assist in developing robust compliance programs that satisfy ongoing recordkeeping, training, business continuity, and disaster recovery requirements.
Among the services we provide to CPOs and CTAs are:
Structuring your commodity pool and CPO entities.
Preparing CPO operating agreement, investment management contract, commodity pool offering memorandum, limited partnership agreement and subscription documents.
Notifying you of potential exemptions you may rely on under Section 4 of the CFTC regulations if an exemption is available to you and helping you comply with the exemptions regulatory requirements.
Preparing and submitting NFA online registration and navigating the account establishment process in order to obtain system access and once system access is granted, preparing and filing CPO registration application Form 7-R and Form 8-R for CPO principals and associated persons.
Preparing disclosure documents which describe CPO investment programs, fees, expenses, risk factors, break even analysis, redemption provisions, performance disclosures and any other necessary information.
Help you answer any questions from NFA compliance personnel in connection with CPO registration and provide ongoing advice on quarterly and annual reporting and regulatory changes.