Kenneth M. Rosenzweig and James M. Brady of Katten Muchin Rosenman LLP recently had an article, National Future Association (NFA) Issues Guidance on Annual Affirmation Requirement for CPO and CTA Exemptions, featured in The National Law Review:
Commencing in 2012, each person or entity claiming an exemption from commodity pool operator (CPO) or commodity trading advisor (CTA) registration must annually affirm the applicable exemption within 60 days of the end of each calendar year. Any person or entity that does not affirm its applicable CPO or CTA exemption will be deemed to have requested to withdraw the exemption. The affirmation process can be completed through the National Future Association’s online exemption system.
More information is available here.