The National Futures Association issued two Interpretive Notices that will affect all private fund managers that are NFA members (i.e., managers with funds or accounts that trade commodity interests and that are not eligible for an exemption from registration with the Commodity Futures Trading Commission). While the Interpretive Notices address different areas of risk — one is focused on the need for more formal supervision of key financial functions, and the other is focused on addressing cybersecurity risks — they both require the attention of senior administrative personnel. Given that the obligations set forth in these notices will become effective on April 1, 2019, all affected managers should take steps to ensure timely compliance.
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