CPO and CTA Regulations: Rapid Fire

What this video covers

• Why an NFA compliance rule makes any CFTC disclosure, reporting, or recordkeeping violation also an NFA violation, and what that means for member discipline
• The exact delivery timing for a CPO's Disclosure Document (no later than the subscription agreement) versus a CTA's Disclosure Document (no later than the advisory agreement, plus required signed dated acknowledgment of receipt)
• Why the break-even analysis is a pool-only requirement about fees, not a performance prediction for advisory programs
• The two separate clocks: 12 months for the physical Disclosure Document itself, then 3 months (or 60 days under the alternative method) for the performance figures inside
• The 48-hour cushion when a materially amended Disclosure Document must reach a prospect before a subscription is accepted
• How bunched orders may be combined for efficiency but must be allocated by a pre-established, objective, non-preferential method reviewed at least quarterly
• Why every profit claim needs an equally prominent risk-of-loss discussion, and when audio or video promotional material must be submitted to NFA review at least 10 days before first use