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NFA: Forex Dealer Member Update & CPO & CTA Affirmation Req. Exemptions

NFA Proposes Reduction in Forex Dealer Member Assessment on Order Segments

On November 29, the National Futures Association (NFA) proposed an amendment to NFA Bylaw 1301(e) to reduce assessments for each order segment fee a Forex Dealer Member (FDM) submits to NFA’s Forex Transaction Reporting Execution Surveillance System (FORTRESS). Currently, each FDM is required to pay an assessment of $.004 on each order segment submitted to FORTRESS. NFA has proposed lowering the assessment to $.003, and such proposal may become effective as early as 10 days after receipt of the submission by the Commodity Futures Trading Commission (CFTC).

The NFA rule submission is available here.

NFA Issues Notice to Members on Annual Affirmation Requirement for CPO and CTA Exemptions

On December 2, the National Futures Association (NFA) issued Notice I-19-29 reminding NFA members that any person claiming an exemption from commodity pool operator (CPO) registration under CFTC Regulation 4.13(a)(1), 4.13(a)(2), 4.13(a)(3), 4.13(a)(5), an exclusion from CPO registration under CFTC Regulation 4.5 or an exemption from commodity trading advisors (CTA) registration under 4.14(a)(8) must annually affirm the applicable notice of exemption within 60 days of the calendar year end, which is February 29, 2020 for this affirmation cycle. Failure to affirm will result in the exemption being withdrawn on March 1, 2020. The affirmation process can be completed through NFA’s online Exemption System.

The notice and more information on how to complete the affirmation process is available here.

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About this Author

Christian B. Hennion, Finance Attorney, Katten Muchin Law Firm

Christian B. Hennion concentrates his practice in financial services and asset management matters, including counseling fund managers, registered investment advisers and commodity trading advisors on both transactional and regulatory matters. Chris has advised a wide range of US and international managers, from start-ups to large institutions, regarding a variety of matters, including private fund launches and reorganizations, advisory engagements, Investment Advisers Act and Commodity Exchange Act compliance obligations, Securities and Exchange Commission (SEC) and Commodity Futures...

Jack West Financial Attorney Katten

Jack West is an associate in the Financial Markets and Funds practice.