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.