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
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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