Commodity pool operators (CPOs) and Commodity trading advisors (CTAs) are required to
electronically submit to the NFA, an annual questionnaire with basic information about the
CPOs and CTAs and their related entities. The questionnaire must be updated to disclose
material changes to the CPO’s and CTA’s business operations in a prompt manner. The
questionnaire must be reviewed, signed and filed by a person who is both a registered
associated person and listed as a principal of the firm. CPOs and CTAs who answer “No”
to all questions in the questionnaire relating to whether a firm engages in commodity
interest activities will be required to update the commodity interest business portions of
the questionnaire on a bi-annual basis.