Disclosure Documents
Chapters in this video
- 0:00 Why the disclosure document exists: inform before the decision
- 1:02 CPO vs. CTA delivery timing and the signed acknowledgment trap
- 3:07 The two clocks: 12-month document staleness and 3-month performance freshness
- 5:05 Mandatory contents: cover-page legend, fees, conflicts, and five-year backgrounds
- 6:57 Actual versus hypothetical performance and the backtest trap
- 8:03 Rapid-fire exam recap
What this video covers
- The CPO delivery rule: the Disclosure Document must reach the prospect no later than the subscription agreement, with a 48-hour cooling-off period triggered only by material amendments
- The CTA additional hurdle: why delivering the Document is insufficient and the signed, dated acknowledgment of receipt must be in hand before entering the advisory agreement
- The 12-month staleness clock on the Document itself, and why this is separate from the 3-month or 60-day freshness windows that apply only to performance figures inside
- The mandatory cover-page legend stating that the Commodity Futures Trading Commission (CFTC) has not passed upon the merits or the accuracy of the Document
- The five-year business background disclosure required for the operator, trading advisor, and all principals making trading or operational decisions
- The complete fee disclosure rule: management fees, incentive fees, brokerage commissions, and expenses stated in dollar amounts wherever possible, feeding the pool break-even analysis
- Why actual performance and hypothetical or pro forma performance are treated differently, and why backtested results can never be presented as if they were live trading profits
Read the full lesson, free
This video's complete written lesson is free to read in the CertFuel app, no signup wall. The complete Series 3 course also includes adaptive practice questions and spaced-repetition flashcards, free through the end of 2026.