Guidance on the annual affirmation requirement for entities currently operating under an exemption from CPO or CTA registration

The CFTC requires any person that claims an exemption from 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 CTA registration under 4.14(a)(8) (collectively, exemption) to annually affirm the applicable notice of exemption within 60 days of the calendar year end, which is March 1, 2021 for this affirmation cycle.

CFTC/NFA Members Victims of Corporate Identity Theft

Based on the increasing amount of corporate identity theft, every registered firm, regardless of whether they are actively trading or soliciting, should be conducting regular web searches based on the company’s name. Turnkey has witnessed firms, with and without websites, come under NFA scrutiny over an URL they have no relation to.

CFTC/NFA Annual Compliance Obligations

As the unprecedented year of 2020 comes to a close, staff will begin leaving for holiday vacation and compliance will be forgotten.  Turnkey Trading Partners always likes to remind our clients to consider annual compliance deadlines and obligations.