A National Futures Association (“NFA”) member, including a registered commodity pool operator or commodity trading advisor, that employs an associated person (“AP”) at a location other than its main business address must designate such location as a branch office. Each branch office requires a branch office manager that has completed the Series 30 exam.

The NFA issued a Notice to Members today stating that it will not pursue disciplinary action against an NFA member that allows APs to temporarily work from home or other remote locations pursuant to its business continuity plan and in response to the coronavirus (COVID-19), provided that the member implements alternative supervisory methods to adequately supervise the APs’ activities and meet its recordkeeping requirements.

If you have any questions regarding the foregoing, please contact any of the partners or counsel listed below or your primary attorney in Seward & Kissel’s Investment Management Group.