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Hedge Funds Partner Debbie Monson Discusses the NFA’s Interpretive Notice on Certain Virtual Currency Activities Disclosures

Practices: Hedge Funds, Derivatives & Commodities, Compliance for Hedge Funds

An article in the Sept. 20 issue of The Hedge Fund Law Report titled “NFA Mandates New Disclosures on Certain Virtual Currency Activities” explores key provisions of the National Futures Association’s Interpretive Notice regarding disclosures on certain virtual currency activities, in addition to several potential traps for fund managers. Hedge funds partner Deborah Monson is quoted in the piece.

“The Notice is unusual for the NFA, and reflects significant concern over virtual currency activities,” Ms. Monson, told The Hedge Fund Law Report. “For ‘full Part 4’ disclosure documents, NFA reviewers have been requiring virtual currency risk factors on an ad hoc basis since at least the beginning of the year. Thus, written guidance is helpful because it informs filers of the requirements in advance and produces more uniform staff comments,” Ms. Monson noted. In light of the Notice, CPOs and CTAs should “thoughtfully tailor risk disclosures.”

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