The National Futures Association ("NFA") reminded members of their ongoing obligation to update the firm-level section of the annual questionnaire to reflect virtual currency transactions.
Since December 2017, the NFA required commodity pool operators ("CPOs"), commodity trading advisors ("CTAs") and introducing brokers ("IBs") to notify the NFA if they are engaged in virtual currency transactions, whether executing or only soliciting or accepting orders. The NFA issued the reminder on Notices I-17-28 and I-17-29 (the "Notices") and noted additional reporting obligations for CPOs, CTAs and IBs that are not yet required for filing.
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