CFTC/NFA – Regulatory Recap – November 2019

NFA Compliance Rules 2-29 and 2-36 and related Interpretive Notices establish requirements for a Member’s communications with the public and use of promotional material. NFA recently amended these requirements to clarify their applicability, better reflect current technology and business practices and address the use of hypothetical performance in promotional material by commodity pool operator (CPO) Members operating pursuant to a CFTC Regulation 4.7 exemption. These amendments will become effective on January 1, 2020.

Higher NFA Fees For Swap Firms: Are you Effected?

NFA’s membership fee increase is scheduled to go into effect January 1, 2020. Invoices for this surcharge will be scheduled to go out around November 15, 2019. Now is the time for NFA member firms to revisit whether or not their brokerage activities fall under NFA’s new swap firm considerations.