Over the last few years, the NFA has paid greater attention to the internal controls systems used by members, particularly with respect to handling and safekeeping customer funds, as well as financial reporting. Based on data gained from this practice, the NFA’s Board of Directors has stated that it believes that an internal controls system is the foundation for producing reliable financial statements, and deterring errors and fraudulent activity by employees, management and third parties. To that end, the NFA recently submitted a Proposed Interpretive Notice (Notice) to the CFTC that will take effect on April 1, 2019. The Notice requires commodity pool operators (CPOs) that accept, hold and redeem customer funds to have internal controls systems that address the safeguarding of customer funds, as well as provide reasonable assurance that the books and records of the CPOs’ commodity pools are reliable and that the CPOs are in compliance with all CFTC and NFA requirements. This article summarizes the key elements of the Notice, with commentary from a former CFTC attorney. For another recent development on regulation of CPOs, see “CFTC Proposes Amendments to Regulations to Codify Existing Relief for CPOs and CTAs” (Nov. 15, 2018).