CCO Resource Hub: National Futures Association (NFA)

Chief Compliance Officer Committee

National Futures Association: Examination Materials 

Those members whose business triggers registration with the Commodity Futures Trading Commission (CFTC) as a Commodity Pool Operator (CPO) or otherwise may be subject to examination by the National Futures Association (NFA).  To enable members to prepare for such exams, this section of the Resource Center includes the document request lists and questionnaire the NFA requires CPOs to complete as part of a review.  Please note that, according to our members that have been the subject of these examinations, the NFA staff is not familiar with how funds are organized, how we operate, or how we are regulated by the SEC.  Indeed, they seem to approach these exams as focused on cash audits and it is not uncommon for them to require a mutual fund CPO to send asset verification letters to their institutional clients.  Here are the NFA-related documents CCOs have shared with us to date:

• NFA Document Request List (February 2021)
• NFA CPO Internal Controls Questionnaire (February 2021)

The documentation provided by ICI that may be accessed by committee and task force members is restricted to members use only and not for distribution or reproduction. Documentation may be used internally at member organizations as needed to facilitate committee and task force initiatives.