CTAs and CPOs Beware; Required Disclosure Updates Apr 09, 2020 During these unprecedented times many firms are seeing temporary and permanent changes to how they are conducting business. As firms adjust to the Covid-19 pandemic, one area that Turnkey Trading Partners (“Turnkey”) has seen being largely overlooked is Commodity Trading Advisor (“CTA”) and Commodity Pool Operator (“CPO”) obligations to update offering and disclosure documents, as well as, marketing materials for material events. Within this article we will look at how the pandemic could affect and require a CTA or CPO to update both offering documents as well as marketing materials.
World Stops; CFTC & NFA Compliance March On Mar 26, 2020 With the ongoing concerns surrounding COVID-19, news is moving fast. That means government agencies, businesses, and whole industries are having to respond quickly. As of today (March 26, 2020) the National Futures Association (“NFA”) and Commodity Futures Trading Commission (“CFTC”) have issued several notices.
CTA Performance Reporting and Allocation Variance Feb 28, 2020 NFA audits evaluate many compliance items. An area not often discussed is performance reporting, bunched or blocked orders, and what is or is not acceptable rate of return variance for CTA and CPO registrants. This article discusses these points and Turnkey’s experienece with them over the years.