While changes to the SEC’s proposed advertising rule changes and proxy voting requirements may be getting a lot of attention as the end of 2019 approaches, newly-effective changes in this area from the National Futures Association (NFA) have been getting less attention but will apply from 1 January 2020.
Registered commodity pool operators (CPOs) and commodity trading advisors (CTAs) will need to come to grips in the near term with changes to the NFA’s promotional materials rules and interpretations, newly-adopted amendment to the Commodity Futures Trading Commission’s Part 4 Regulations and a new regime for the training and testing of associated persons’ market knowledge and their knowledge of the regulatory requirements related to swaps. This is in addition to all the usual year end housekeeping for CPO/CTA compliance.
With all of these pieces in motion, K&L Gates’ Stephen Humenik, Cary Meer and Edgar Mkrtchian present a refresher on the things that CPOs and CTAs need to address in 2020.