Fund managers relying upon exemptions from registration as commodity pool operators (CPOs) pursuant to CFTC Rule 4.13(a)(1), 4.13(a)(2), 4.13(a)(3) or 4.13(a)(5) (or an exclusion in the case of CFTC Rule 4.5) must re-affirm their exemptions on file with NFA by March 2, 2015. While the re-affirmation filing is the responsibility of the CPO, introducing brokers (IBs) that do business with exempt CPOs need to ensure annually that CPOs that they do business with are properly exempt. Failure to do so could result in a violation of NFA Bylaw 1101, which provides that no NFA Member (including IBs and CPOs) shall…