A hedge fund manager may be subject to CFTC jurisdiction and registration as a commodity pool operator (CPO) or commodity trading adviser (CTA) if it uses derivatives or trades in commodities.  See “Do You Need to Be a Registered Commodity Pool Operator Now and What Does It Mean If You Do (Part One of Two),” Hedge Fund Law Report, Vol. 5, No. 8 (Feb. 23, 2012); and Part Two of Two, Vol. 5, No. 19 (May 10, 2012).  A CPO or CTA is required to become a member of the National Futures Association (NFA) and, as such, is subject to NFA rules and regulations and to periodic audits.  In that regard, a recent program reviewed the nuts and bolts of an NFA audit, NFA compliance programs and common audit issues; offered strategies for preparing for and surviving an audit; and summarized recent CFTC guidance that affects CPOs and CTAs.  The program featured Robert V. Cornish, Jr., a partner at Phillips Lytle LLP; Dorothy D. Mehta, a special counsel at Cadwalader, Wickersham & Taft LLP; Deborah A. Monson, a partner at Ropes & Gray, LLP; and Heather Wyckoff, counsel at Haynes & Boone LLP.  See also “NFA Workshop Details the Registration and Regulatory Obligations of Hedge Fund Managers That Trade Commodity Interests,” Hedge Fund Law Report, Vol. 5, No. 47 (Dec. 13, 2012).