Foreside provides comprehensive and tailored compliance services to Commodity Pool Operators (CPOs) and other National Futures Association (NFA)-registered entities. Employing seasoned compliance professionals and attorneys who have worked extensively with NFA-registered firms, our services span a broad spectrum, including assisting our clients with satisfying Commodity Exchange Act requirements as interpreted, implemented, and enforced by the Commodity Futures Trading Commission (CFTC) and the NFA.
Foreside’s services are generally offered in three stages, shown below. We will also accommodate other service models to meet the needs of clients and business partners in this space.
Stage 1- CPO/CTA Registration
- Assist with your entity’s registration as a CPO, CTA, and Swap Firm Designation.
- Assist with the registration of personnel to become Principals, Associated Persons, and/or Swap Associated Persons of the CPO/CTA.
Stage 2 – Develop a CPO Compliance Program
- We will work with your firm to develop Written Supervisory Procedures (WSPs) and a customized Compliance Program Risk and Organizational Matrix for each of your commodity pools.
- If you have an existing compliance program that requires modification to incorporate rules and regulations of a CPO, we will conduct a gap analysis aimed at leveraging your firm’s existing policies and procedures. This will allow you to administer a robust compliance program while avoiding the costly, fixed expenses associated with hiring in-house compliance specialists and attorneys.
Stage 3 – On-going CPO Compliance Consulting
We will assist you with your specific compliance needs, including each CPO’s annual & quarterly NFA obligations, in addition to:
- Annual questionnaires and registration updates.
- Annual renewal filings to secure exemptive relief relevant to the CPO/CTA’s organizational structure/operating environment.
- Self-examination checklists.
- Business continuity reviews.
- Ethics training sessions, led by our professionals and tailored to your firm’s operating environment.
- Quarterly CPO filings.
- Financial statement filings.
- Mock NFA examinations.
- We will train your personnel on the requirements of the Compliance Program and the regulatory framework of CPOs, providing insight concerning NFA inspection preparedness.