The National Futures Association's proposed virtual currency
disclosure requirements would be applicable to futures commission
merchant, introducing broker, commodity pool operator, and
commodity trading advisor member firms. In its interpretive notice,
NFA expressed concerns about whether customers fully understand the
valuation issues, lack of regulatory oversight, and substantial
risk of loss associated with virtual currencies.
The National Futures Association (NFA) has proposed new disclosures applicable to futures
commission merchants (FCMs), introducing brokers (IBs), commodity
pool operators (CPOs), and commodity trading advisors (CTAs) that
could require firms to repaper existing disclosure documents,
offering documents, and promotional materials. NFA's concerns
regarding CPO and CTA member firms' activities in virtual
currencies arise out of several issues unique to those instruments.
For example, virtual currency derivatives may experience
significant price
