Does a CTA always have to file a disclosure document with NFA?
Not necessarily. A registered CTA that is required to provide a disclosure document must file it with NFA, but an exemption may apply. For example, a disclosure document is not required for a CTA that offers it’s services solely to qualified eligible persons if it meets the requirements for an exemption under CFTC Regulation 4.7. If a disclosure document is required, it cannot be used until it is reviewed and accepted by NFA.