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ARTICLE · 24 OCTOBER 2025

NFA Updates Digital Asset Obligations

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On 17 October 2025, the National Futures Association (NFA) announced that it will be eliminating interpretive guidance requiring digital assets-related disclosure obligations for NFA members.

United StatesFinance and Banking
Sarah V. Riddell
Sarah V. Riddell
Gustavo De La Cruz Reynozo
Gustavo De La Cruz Reynozo

On 17 October 2025, the National Futures Association (NFA) announced that it will be eliminating interpretive guidance requiring digital assets-related disclosure obligations for NFA members. The NFA Board unanimously concluded that NFA Interpretive Notice 9073 (Disclosure Requirements for NFA Members Engaging in Virtual Currency Activities), which was originally adopted by the NFA to require members to disclose specific risks associated with their digital asset activities and inform customers that the NFA does not have jurisdiction over spot digital assets, was outdated and should be reevaluated. The NFA expects to propose updated disclosure requirements in the future after it receives input from impacted members. In the meantime, commodity pool operators (CPOs) and commodity trading advisors (CTAs) remain obligated to appropriately disclose material risks related to their offerings (regardless of asset class).

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