In late January 2014 the National Futures Association (“NFA”) announced to its membership they were: “…reviewing the current regulatory structure applicable to Commodity Pool Operator (“CPO”) and Commodity Trading Advisor (“CTA”) operations. In particular, NFA is looking at ways to strengthen the regulatory structure governing CPO operations to provide greater protection for customer funds… [and] exploring ways to ensure that CPOs and CTAs have sufficient assets to operate as a going concern.” NFA then solicited input from its membership (now the general public) regarding the concept of imposing a capital requirement on its CPO and CTA members for the first…