Under NFA Compliance Rule 2-52 and Interpretive Notice 9082, starting October 15, any commodity pool operator ("CPO") or commodity trading advisor ("CTA") registered with the National Futures Association ("NFA") must designate an individual who is both a registered associated person and an NFA-listed principal to submit the NFA member questionnaire. That person must be sufficiently knowledgeable about the firm's ongoing business lines.

In addition, NFA members will be required to promptly update their questionnaire if there are any material changes to the firm's business—and any such update must be reviewed and submitted by the NFA-listed principal.  Any NFA firm that indicates in its questionnaire that it is not engaged in commodity interest products will be considered "inactive" and will be required to submit certain questionnaire responses semi-annually.