The National Futures Association stated that members will not be in violation of its prohibition against conducting business with nonmembers required to be registered with the Commodity Futures Trading Commission and members of the NFA if they engage in business with certain commodity trading advisors and commodity pool operators from January 1 through March 31, 2015. These CTAs and CPOs were previously exempt or excluded from CFTC registration and had an appropriate notice of exemption on file with NFA. Since such entities are required to file a notice affirming the appropriate exemption or exclusion or CPO registration 60 days from the end of each calendar year—or by March 2 this year—it is possible that a member may have no ability to conclusively confirm the legitimacy of a claimed exemption or exclusion during this interim time. To take advantage of this relief, members must take “reasonable steps” to assess the membership status of persons who claim exemption from CPO or CTA registration with whom it conducts business by reviewing entries on NFA’s BASIC system as well as a spreadsheet NFA is updating nightly to include a list of all persons that have exemptions that require affirmation.