NATIONAL FUTURES ASSOCIATION CPO/CTA REGULATION SEMINAR
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NATIONAL FUTURES ASSOCIATION CPO/CTA REGULATION SEMINAR DISCLOSURE DOCUMENT AND PERFORMANCE REPORTING MARCH 2, 2010. David M. Matteson Drinker Biddle & Reath Chicago Office. Disclosure Document - Goals. Comply with CFTC Part 4 rules Get document cleared by NFA in order to solicit clients

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NATIONAL FUTURES ASSOCIATION CPO/CTA REGULATION SEMINARDISCLOSURE DOCUMENT AND PERFORMANCE REPORTINGMARCH 2, 2010

David M. Matteson

Drinker Biddle & Reath

Chicago Office


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Disclosure Document - Goals

  • Comply with CFTC Part 4 rules

  • Get document cleared by NFA in order to solicit clients

  • Provide important disclosures to investors to protect CPO/CTA from anti-fraud liability


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Common Deficiencies

  • Unclear fee descriptions

    • Timing of management fees (beginning of period or arrears)

    • Incentive fee (trading profits or NAV; interest income; treatment of P&L for notional value)

  • Business background and biographies – must coincide exactly with BASIC

  • FCM litigation

  • Performance capsules (discussed later)


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Timing

  • Disclosure document goes stale every 9 months

  • Allow sufficient time for NFA review and multiple filings

  • Leaving insufficient time could disrupt ability to solicit

  • Material changes also trigger obligation to amend and re-file


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