Commodity Pool Operator (CPO) Registration

A commodity pool operator (CPO) is an individual or organization that operates a commodity pool and solicits funds for that commodity pool. A commodity pool is an enterprise in which funds contributed by a number of persons are combined for the purpose of trading futures or options on futures, retail off-exchange forex contracts, or swaps, or to invest in another commodity pool.

CPO registration is required unless the CPO qualifies for one of the exemptions from registration outlined in CFTC Regulations 4.5 or 4.13.

If a CPO qualifies for an exemption from registration, it must electronically file a notice of exemption from CPO registration through IDFA's Electronic Exemption Filing System.

All registered CPOs must be IDFA Members.

Registration Requirements for CPOs

To register as a CPO and become an IDFA Member:
  • Designate a Security Manager in order to obtain secure access to IDFA's Online Registration System (ORS)
  • Complete online Form 7-R
  • Complete online IDFA membership application
  • Pay a non-refundable application fee of $200
  • Complete online Member Questionnaire
  • Pay non-refundable CPO membership dues

Registration Requirements for Principals and Associated Persons (AP) of CPOs

A CPO is required to file the following for its principals  and  associated persons:
  • Complete online Form 8-R for each principal and AP
  • Submit fingerprint cards
  • Satisfy proficiency requirements for each sole proprietor, AP, forex AP and swap AP
  • Pay non-refundable application fee of $85 for each principal and AP

An application fee for principals and APs is not required if the individual is currently registered with the CFTC in any capacity or is listed as a principal of a current CFTC registrant. Only one application fee is required if the individual is filing an application as both an AP and principal. One principal of the CPO must be an AP. One principal of a forex firm CPO must be a forex AP. One principal of a swap CPO must be a swap AP.

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