New NFA Quarterly Filing Requirements for all Registered CTAs: Action Required

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The U.S. National Futures Association (NFA) has announced its eagerly anticipated new quarterly filing requirement for commodity trading advisors (CTAs).  Such requirement will begin with the reporting of third quarter 2013 data (i.e., September 30, 2013) for all CTAs that are registered with the U.S. Commodity Futures Trading Commission (CFTC) and members of the NFA. The filing requirement under NFA Compliance Rule 2-46 (NFA Form PR) apply to all CTAs regardless of whether they are currently active. The NFA’s notice can be accessed here.  The first NFA Form PR filing will be due November 14, 2013.

CTAs are already subject to a similar CFTC filing requirement in the form of the CFTC’s Form CTA-PR, an annual filing required within 45 days of the end of each calendar year (i.e., by February 14).

On initial review, NFA Form PR contains more questions and requires additional data beyond what is required on CFTC Form CTA-PR. Therefore, as third quarter-end approaches, CTAs must familiarize themselves with the form and instructions, be cognizant of the type of data needed in order to comply with this new risk reporting obligation, and be in a position to collect and sort such data to facilitate filing NFA Form PR. A sample NFA Form PR template can be accessed here.

Dechert will be studying the new form, listening in on the upcoming NFA webinar on this new filing (date TBD and open to all), and expects to issue further commentary in due course. 


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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