NFA Compliance Rule 2-46 requires, with limited exceptions, commodity pool operator (CPO) Members to file NFA Form PQR on a quarterly basis with NFA for each pool that it operates. CFTC Regulation 4.27 imposes similar CPO reporting requirements by requiring CPOs to file CFTC Form CPO-PQR.

In October, the CFTC adopted several amendments to CFTC Regulation 4.27. The CFTC’s final rule:

• Eliminates certain schedules and questions from its Form CPO-PQR;
• Adds new questions to its Form CPO-PQR seeking Legal Entity Identifiers (LEI) for the CPO and the pools it operates, to the extent that they have LEIs;
• Adopts a uniform quarterly reporting schedule for CFTC Form CPO-PQR for all CPOs, regardless of assets under management;
• Eliminates substituted compliance for dually registered CPO investment advisers filing joint Form PF in lieu of CFTC Form CPO-PQR; and
• Permits CPOs to file NFA Form PQR in lieu of the revised CFTC Form CPO-PQR.

Although the CFTC is not requiring a December 31, 2020 CPO-PQR filing, NFA Member CPOs are required, pursuant to NFA Compliance Rule 2-46, to submit the December 31, 2020 NFA Form PQR to NFA via EasyFile (Quarterly Reports) by March 31, 2021.

In light of the CFTC’s amendments, NFA modified its Form PQR to capture LEIs, eliminated certain questions and schedules related to reporting thresholds and made minor organizational and help text changes. These changes will be effective with the December 31, 2020 filing.

The updated PQR template will be available on NFA’s website on December 21, 2020. For XML filers, an updated schema will also be available in the XML Documentation section of EasyFile (Quarterly Reports). Note that CPO Members must update their systems used to generate XML documents to reflect the updated schema.