Earlier this year, the National Futures Association (NFA) put forth guidance to commodity pool operators (CPOs) on the regulator’s Compliance Rule 2-9 that took effect on April 1. The guidance (aka “the Notice”) applies to CPOs with control over customer funds. It outlines what CPOS should be doing to manage employees and how they should be supervising third parties in order to meet their obligations under the new rule focused on internal controls.
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