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Investment Management, Trading & Markets Advisory: Annual CPO or CTA Exemption or Exclusion Affirmations Due by February 29, 2016; Filings Now Accepted

Reported by JD Supra
Feb 2, 2016· 2 min read
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Key Takeaways
  • • Firms claiming CFTC exemptions or exclusions from registration as commodity pool operators (CPOs) or commodity trading advisors (CTAs) must file annual affirmations by February 29, 2016, according to an Alston & Bird advisory.
  • • The CFTC's National Futures Association (NFA) filing system for these annual affirmations was open for submissions as of the advisory's publication.
  • • The requirement applies to registered and exempt operators that rely on specific CFTC exemptions or exclusions, making timely filing a compliance priority for affected managers.
Summary
Alston & Bird, a law firm, published an advisory on February 2, 2016 reminding firms that rely on exemptions or exclusions from registration with the Commodity Futures Trading Commission (CFTC) that annual affirmations are due by February 29, 2016. The obligation applies to any firm currently claiming an exemption or exclusion from CFTC registration as a commodity pool operator (CPO) or commodity trading advisor (CTA).

According to the advisory, filings are now being accepted. Firms subject to the requirement must affirm their continued eligibility for the relevant exemption or exclusion within the annual window. The source material provided is limited to the publisher summary and the advisory's headline, and it does not detail specific filing procedures, penalties for late filing, or the full scope of qualifying exemptions.

For investment managers, family offices, and alternative fund sponsors operating under CFTC relief, the deadline is a compliance item that requires timely attention ahead of the end-of-February cutoff. Managers should confirm their exemption status and submit affirmations within the filing window to remain in good standing.

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Sources

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AlphaMaven summarised this story from the reporting below. Each link opens the original article.

JD Supra Investment Management, Trading & Markets Advisory: Annual CPO or CTA Exemption or Exclusion Affirmations Due by February 29, 2016; Filings Now Accepted