In an effort to better understand and monitor the financial health of certain members of the National Futures Association (“NFA”), the NFA has submitted a proposal to the Commodity Futures Trading Commission (“CFTC”) that would require commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) to report additional information about their financial condition on a regular basis. The recent proposal comes two years after NFA previously sought comments on possible minimum net capital requirements for CPOs and CTAs. Financial reporting may not, at first blush, seem as onerous as minimum net capital requirements. However, financial reporting will nonetheless require the…