Commodity pool operator ("CPO") and commodity trading advisor ("CTA") NFA Members are generally required to provide customers with a Disclosure Document that includes material information so as to permit customers to make an informed decision before investing.1 Among other things, the Disclosure Document must include a full description of any actual or potential conflicts of interest, including any arrangement whereby the Member or any principal thereof might benefit directly or indirectly from requiring the maintenance of accounts with a specific futures commission merchant ("FCM") or the introduction of accounts through a particular introducing broker ("IB"), such as payment for order flow or soft dollar arrangements.2 This description must include, at a minimum, a disclosure that such an arrangement might act as an incentive for the CPO/CTA to overtrade the account to generate more commission revenue for the FCM and/or IB.