May 14, 2021

Volume XI, Number 134

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NFA Issues Notice Regarding Effective Date of NFA’s Rules Regarding CPO Notice Filing Requirements

On April 13, the National Futures Association (NFA) issued Notice I-21-15 advising members firms that new NFA Compliance Rule 2-50 and its related Interpretive Notice become effective June 30. (The proposal of the new rule and Interpretive Notice was discussed in the March 12, 2021 edition of Corporate & Financial Weekly Digest.)

Compliance Rule 2-50 requires a CPO member to promptly notify NFA if it:

  • operates a pool that cannot meet its margin call(s);

  • operates a pool that is unable to satisfy redemption requests in accordance with its subscription agreements;

  • operates a pool that has halted redemptions (not related to existing gates or lockups, or a pre-planned cessation of operations); or

  • receives notice from a swap counterparty that a pool it operates is in default.

The related Interpretive Notice further describes each of the notification events identified in Compliance Rule 2-50 and provides guidance on whether specific events are deemed to trigger the requirement.

NFA Notice I-21-15

Alexander C. Kim also contributed to this article.

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©2021 Katten Muchin Rosenman LLPNational Law Review, Volume XI, Number 106
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About this Author

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

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...

312-902-5521
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