National Futures Association (NFA) has requested comments from its commodity pool operator (CPO) and commodity trading advisor (CTA) members on whether to adopt capital requirements to ensure that CPOs and CTAs have adequate funds to operate as a going concern. NFA has also requested comments on other customer protection and related measures, including the following: (i) whether an independent third party should review and authorize a CPO’s disbursement of pool funds; (ii) whether an independent third party should prepare or verify a pool’s monthly or quarterly account statements and performance results; (iii) whether depositories with accounts holding customer funds for a pool should report the balances in those accounts to NFA on a daily basis; and (iv) whether inactive CPO/CTA members should remain NFA members. 

NFA’s notice to members is available here.