NFA BYLAW 1101: APPLICATION OF NFA BYLAW 1101 IN VARIOUS COMMON SCENARIOS If you are member of the National Futures Association (“NFA”), you have probably heard that you are required to abide by NFA’s Bylaw 1101 (“Bylaw 1101”) due diligence obligations in connection with the operation of your firm. Bylaw 1101 prohibits NFA Members (“Members”) from conducting business with or on behalf of non-NFA Members. In this regard, NFA imposes strict liability on its Members for violations of Bylaw 1101, with enforcement cases primarily issued in instances where the NFA staff believes that the Member “knew or should have known…