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DRAFT — pending legal review

This page is a draft written by the team; it takes effect only when a lawyer releases it, and nothing on it is investment advice.

CFTC Rule 4.41 Notice

The statement U.S. rules prescribe for simulated or hypothetical performance, why it sits next to every number we show, and where the text comes from.

Version
1.0.0
Effective
Not yet in effect
Applies to
quant24.io and beta.quant24.io during pre-launch
Last updated
2026-09-05

Every performance number this Service is designed to produce comes from a simulation. U.S. rules say that when simulated or hypothetical results are shown, a specific statement must be shown with them. This page is that statement, where it comes from, and where we apply it.

What the rule says

17 CFR §4.41 governs advertising by commodity pool operators, commodity trading advisors and their principals. Paragraph (b)(1) is the part that matters here: no person may present the performance of a simulated or hypothetical commodity interest account or transaction unless the presentation is accompanied by one of two statements.

The first, at §4.41(b)(1)(i), is written into the regulation itself. It is the one we use, and it is reproduced verbatim:

CFTC Rule 4.41(b)(1)(i) — Hypothetical performance disclosure

These results are based on simulated or hypothetical performance results that have certain inherent limitations. Unlike the results shown in an actual performance record, these results do not represent actual trading. Also, because these trades have not actually been executed, these results may have under-or over-compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated or hypothetical trading programs in general are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any account will or is likely to achieve profits or losses similar to these being shown.

The statement above is the text of 17 CFR §4.41(b)(1)(i), quoted exactly, including its punctuation.

The second, at §4.41(b)(1)(ii), is "a statement prescribed pursuant to rules promulgated by a registered futures association". In practice that means the legend in NFA Compliance Rule 2-29(c) — the long all-caps paragraph that begins "HYPOTHETICAL PERFORMANCE RESULTS HAVE MANY INHERENT LIMITATIONS". It is the version most trading sites show. Quant24 is not a member of the National Futures Association, so that alternative is not ours to use, and labeling it "CFTC Rule 4.41" would be inaccurate. We use the text the regulation itself prescribes.

Where it has to appear

§4.41(b)(2) adds a placement rule: when the presentation is not oral, the prescribed statement "must be prominently disclosed and in immediate proximity to the simulated or hypothetical performance being presented". A notice buried in a footer, or on a page you have to go looking for, does not satisfy it.

So the notice travels with the number, not with the site:

  • Under every chart, equity curve, table of metrics and probability we display, on the website and in the application.
  • In the Evidence Ledger of every strategy, next to the results of the tests that produced it.
  • In any report or export that carries a simulated result out of the Service.
  • In this build, that means everywhere a performance number exists: no result here comes from a market, so no result here is exempt.

Alongside it, every simulated number carries a SYNTHETIC badge, and real and simulated figures are never mixed in the same view.

Where the text comes from

The statement on this page was read from the source, not copied from another site: the eCFR public API, for the 2026-09-02 issue of Title 17, on 4 September 2026.

That verification is the work of our build process, not of a lawyer. Like every legal page on this site it is marked DRAFT — pending legal review until counsel releases it.

What this notice is not

It is not a statement that Quant24 is registered with the Commodity Futures Trading Commission, a member of the National Futures Association, or an entity that Rule 4.41 addresses by its terms. We are none of those: Quant24 is software, we hold no client funds, we manage no accounts, and we give no personalized advice. We show the statement because we show simulated results, and because a reader deciding what to believe about a number deserves the same warning a regulated advertiser would have to give.

For the risks the statement alludes to, in plain words, see the Risk Disclosure. For the agreement that governs all of this, see the Terms of Service.

Questions: b.caldera@quant24.io.