Disclosure Documents

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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

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