CPO Services
Unique for an administrator, Marathon is registered with the CFTC as a commodity pool operator (“CPO”) and a member of the NFA. This allows Marathon to not only perform the role of fund administrator but also to act as a fund’s CPO and assume all of the responsibilities and duties of being the CPO for the fund that the CTA manages.
As a result, the CTAs that partner with Marathon do not need to be registered as a CPO and do not need to comply with the numerous rules and regulations that apply to such registrants; instead, the firm can focus its full efforts on growth and producing returns.
Marathon’s services include, but are not limited to, the following:
- Drafting offering document and subscription documents
- Forming the investment fund under state law
- Preparing the monthly investor statements
- Sending statements to investors
- Making required filings with applicable government agencies, including the SEC, CFTC, NFA, IRS, and state agencies
- Making NFA quarterly and annual filings
- State filings with a place of formation
- Responding to investor questions and requests
- Reviewing tear sheets and other promotional pieces for compliance with applicable requirements
- Getting NFA approval of offering document/disclosure document or file 4.7 notice with the NFA
- Filing Form D with the SEC
- Making expenditures for or on behalf of a fund
- Distributing the annual certified financial report to investors
- Complying with anti-money laundering requirements
- Retaining and working with an independent certified public accountant that prepares the annual certified financial report
- Reviewing completed subscription documents for compliance with applicable requirements
- Calculating fees and Net Asset Value
- Preparing and keeping its books
- Completing blue sky filings with states security agencies
- Processing redemption requests
- Dealing with the NFA when it comes to the fund
- Maintaining all applicable records
