Commodity Trading Advisers
Commodity Trading Advisers
RW routinely registers commodity trading advisers with the CFTC and develops accurate and comprehensive disclosure documents.
Due to recent regulatory changes, there are few if any exemptions to registration with Commodity Futures Trading Commission left for managers and investment advisers trading commodity futures, options on futures or currencies contracts for separately managed accounts. RW routinely registers commodity trading advisers with the CFTC and develops accurate and comprehensive disclosure documents. Included in RW’s registration services are the following:
- Structure and establish the CTA firm as a legal entity;
- Prepare the CTA firm operating agreement establishing parameters for the firm and its internal controls;
- Prepare investment management agreements for the CTA;
- Complete comprehensive CTA questionnaire outlining all pertinent aspects of firm’s business;
- Complete and file Form 7-R and Form 8-R;
- Complete and file disclosure documents for regulatory approval and distribution to clients;
- Draft disaster recovery and business continuity plan, written organizational policies and procedures per NFA rules; and
- Liase with CFTC and NFA to expedite registration process.
On an on-going and annual basis, RW assists CTAs in complying with CFTC and NFA requirements including the following:
- Complete electronic Annual Registration Update and Questionnaire;
- Complete NFA’s annual self-examination checklist;
- Update and file firm’s disclosure documents more than 9 months old if soliciting new;
- Distribute current firm privacy policy to every client and investor;
- Ensure ethics training is provided as outlined in firm’s compliance materials; and
- Test firm’s disaster recovery plan and address any issues.