• CPOs, CTAs and Other CFTC Intermediaries to Use New Self-Examination Questionnaire
  • October 14, 2015
  • Law Firm: Sutherland Asbill Brennan LLP - Washington Office
  • The National Futures Association (NFA), which is the self-regulatory organization for the derivatives industry, has released an updated version of the annual Self-Examination Questionnaire to be used by NFA members. This update follows the CFTC’s adoption of Rule 170.17 mandating NFA membership for all registered introducing brokers (IBs), commodity pool operators (CPOs), and commodity trading advisors (CTAs), other than CTAs that are eligible to rely on the exemption from registration under CFTC Regulation 4.14(a)(9). The questionnaire is used by CFTC intermediaries, including futures commission merchants (FCMs), forex dealer members (FDMs), IBs, CPOs and CTAs, when evaluating their business and operations and to determine compliance with regulatory requirements as well as if there are appropriate internal policies and procedures. Updates were made to reflect recent amendments to NFA rules and CFTC regulations to: (1) the general self-examination questionnaire for all members, (2) all of the supplemental questionnaires for the different types of intermediaries, and (3) Appendix B, the Business Continuity and Disaster Recovery Plan Questionnaire.