On April 8th, the National Futures Association (“NFA”) issued its Notice to Members I-15-13 (the “NTM”), which will be of interest to:
1) Any commodity pool operator (CPO) relying on CFTC No-Action Letters 14-69 or 14-126 in order to delegate certain of their oversight responsbilities as a CPO to another registered CPO; and
2) Any NFA member conducting due diligence pursuant to NFA Bylaw 1101 with respect to the status of a CPO as being properly registered or exempt from registration.
In sum, the NTM describes updates that were made to the NFA’s EasyFile system in order to allow a registered CPO to notify the NFA that another CPO has delegated to the registered CPO the investment management authority over a particular pool.
Continue Reading Attention Hedge Funds: NFA Updates EasyFile System to Allow For CPO Delegation Under CFTC No-Action Letters 14-69 and/or 14-126