On April 14, 2020, the Commodity Futures Trading Commission (CFTC) proposed, among other things, to narrow and revise the scope of information that it collects from commodity pool operators (CPOs) on its Form CPO-PQR to:

• Eliminate the pool-specific reporting requirements in existing Schedule B (except for the schedule of investments) and C.
• Amend Schedule A to require legal entity identifiers (LEIs) to be provided for the CPOs and their operated pools that have them.
• Eliminate questions regarding auditors and marketers.

Under the proposed rule amendments, all CPOs, regardless of the amount of pool assets under management, will be required to file the same form on a quarterly basis and, after the National Futures Association (NFA) amends its Form PQR to require LEIs, CPOs could simply file NFA Form PQR in lieu of the proposed form. Because Form PF principally permits pool operators to incorporate information from Form PF into Schedules B and C, CPOs would no longer be able to satisfy CPO filing obligations through filing Form PF. 

The CFTC intends to use information that it could obtain on a real-time basis from derivatives clearing organizations and swaps data repositories that is or would be associated with the pool or CPO’s LEI to monitor the markets and the passing of risks after the adoption of the amendments to the CPO-PQR.