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