CFTC/NFA Registrant PPP Guidance

On April 23, 2020, the CFTC issued a no-action letter to futures commission merchants (FCM) and introducing brokers (IB) addressing the net capital treatment of covered loans obtained under the Paycheck Protection Program (PPP) and unpaid FINRA assessment fees. PPP is a component of the Coronavirus Aid, Relief, and Economic Security Act administered by the Small Business Association.

NIBA Makes Request to CFTC for No-Action Position

NIBA recently published information regarding the CARES act and how its members can navigate the process should they choose to do so.  Looking a few steps ahead the natural question became – are there compliance and regulatory considerations for firms that apply for and receive relief? 

CTAs and CPOs Beware; Required Disclosure Updates

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.