NFA set an effective date of June 30, 2021, for recently adopted Compliance Rule 2-50 and a related interpretive notice requiring a CPO to notify NFA upon an event that may affect the ability of its pool to fulfill its obligations to pool participants.
As previously covered, the events that would trigger NFA Compliance Rule 2-50 include:
- a pool operated by the firm is unable to meet its margin calls, including where the amount of the call is disputed;
- a pool operated by the firm cannot satisfy redemption requests in accordance with its subscription agreements;
- a pool operated by the firm halts redemptions other than pursuant to the terms of preplanned events; or
- a swap counterparty notifies a CPO that a pool the CPO operates is in default.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.