NFA member CPOs are required to file on a quarterly basis Form PQR disclosing certain information for each pool that it operates. Last year, the CFTC adopted similar requirements under CFTC Regulation 4.27.
This regulation requires CPOs to file information on CFTC Form CPO-PQR with the CFTC on a quarterly or annual basis, depending on the AUM. It also requires CTAs to make annual filings on the CFTC Form PR.
Both Form PQR and PR are filed with NFA through the electronic EasyFile System.
In order to remove duplicate information, NFA amended Compliance Rule 2-46. NFA has extended reporting deadlines to match CFTC as well as revised its Form PQR to be more comparable to CFTC Form PQR.
Moreover, the amendments impose new quarterly filing requirements on CTAs. NFA has not yet finalized the date of the first required filing. No report will be due for the quarters ended March 31 or June 30, 2013.
Although CFTC Regulation 4.27 bases its filing frequency and content on a CPOs AUM, NFA will continue to require all CPOs to report quarterly under NFA Compliance Rule 2-46.
Small CPOs (AUM less than $150M) do not have a CFTC quarterly filing requirement but they will continue to be required to file NFA’s Form PQR for the quarters ended March, June, and September within 60 days of the quarter end. Small CPOs will satisfy the December 31 quarterly requirement by filing CFTC Form PQR (Schedule A) plus a Schedule of Investments within 90 days of the close of each calendar year end.
All filings for both NFA and CFTC are to be filed through NFAs EasyFile System. For CPOs, the filing consists of both firm and pool level questions. the system will determine what forms are required after the cover page is completed. The applications will be forwarded to the CFTC.