In response to the COVID-19 pandemic, the NFA issued a no action letter with regard to regulatory relief for Commodity Pools.
Per NFA Rule 2-46, the NFA currently requires each CPO member to file the NFA Form PQR on a quarterly basis for each pool within 60 days of three quarters’ end and within 90 days after the 4th quarter. For example, if the fourth quarter end is December 31, 2019, the PQR is due on March 30th and for the quarter ended March 31, 2020 the PQR is due by May 30, 2020.
However, the NFA has extended those due dates. The December 31, 2019 PQR will be extended until May 15, 2020 and the due date for the March 31, 2020 PQR will be extended until July 15, 2020.
The certified annual financial audit submission deadline has been extended from March 30, 2020 to May 15, 2020. Commodity Pools must still distribute periodic account statements to pool participants on a monthly or quarterly basis in accordance with CFTC Regulation 4.7(b) and 4.22(b).
There is no need to apply for the extension with NFA. The extension is automatic.
If you have questions regarding these new deadlines or need assistance with your commodity pool audit, please contact Mike at 630-461-5841 or email mike@cogcpa.com.