NFA recently adopted an Interpretive Notice entitled NFA Compliance Rule 2-9: CPO Internal Controls System (Interpretive Notice). The Interpretive Notice requires commodity pool operator (CPO) Members, which have the ability to control customer funds, to implement an internal controls framework designed to: Protect customer funds; and Provide reasonable assurance that the books and records of a CPO’s commodity pools are accurate and reliable and that the CPO is in compliance with all CFTC and NFA requirements. The Interpretive Notice will become effective on April 1, 2019. In order to demonstrate an adequate internal controls system, the Interpretive Notice also requires…