CPO and CTA Registration is Imminent - The Deadline is December 31, 2012

Managers of private investment funds that must complete CPO/CTA registration with the CFTC must act very quickly to ensure that they are fully registered by the December 31, 2012 deadline. Deadline Please note that the deadline for actually being registered is December 31, 2012; this is not the deadline for submitting the application to register.

Registration Process Takes Time The CFTC registration process is quite involved and can take many weeks to complete. There are several steps involved in the registration process, including preparing and filing applications, studying and passing proficiency examinations (e.g., Series 3 or Series 32 examinations), undergoing background checks, submitting fees and completing fingerprint cards. Importantly, a firm's registration is not complete until the NFA approves it.

CFTC/NFA Compliance Program Required To be compliant with the regulations, NFA-registered firms must develop and implement a compliance program that is specifically designed to be CFTC/NFA-compliant. This program must include written policies and procedures, and it must be in place when the firm's registration becomes effective.

No Time to Waste Given the involved process to become registered, it is strongly recommended that firms complete the application process by mid-November, and that they develop and implement their CFTC/NFA compliance programs promptly. We can provide assistance with these matters.

Cheryl Spratt