The National Futures Association ("NFA") set October 31, 2018 as the effective date for certain disclosure requirements related to virtual currency activities.

In the Interpretive Notice issued in May, the NFA advised futures commission merchants and introducing broker members to supply the NFA Investor Advisory - Futures on Virtual Currencies Including Bitcoin and the CFTC Customer Advisory: Understand the Risks of Virtual Currency Trading to any customer involved in a virtual currency derivative transaction. Additionally, the NFA requires CPO and CTA members to provide investors with "robust disclosures" related to spot and derivatives market virtual currencies, as described in previous coverage.

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