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NATIONAL FUTURES ASSOCIATION CPO/CTA REGULATION SEMINAR DISCLOSURE DOCUMENT AND PERFORMANCE REPORTING MARCH 2, 2010

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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

disclosure document goals
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
common deficiencies
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)
timing
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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