On June 5, the National Futures Association (NFA) announced the issuance of revised Forms CPO-PQR and CTA-PR. The NFA is the self-regulatory organization to which the Commodity Futures Trading Commission (CFTC) has delegated the registration of, and certain oversight functions with respect to, commodity pool operators (CPO) and commodity trading advisors (CTA) (and certain other intermediaries). The amended Forms CPO-PQR and CTA-PR were issued in response to feedback and questions the NFA received from its CPO and CTA members.

Periodic reporting via the submission of Forms CPO-PQR and CTA-PR to the CFTC (via the NFA) is a relatively new requirement. The Forms were adopted by the CFTC in February 2012 as part of a series of new requirements for CPOs and CTAs. The frequency with which CPOs must file Form CPO-PQR varies depending on the amount of assets the CPO has under management. Form CTA-PR is to be filed annually.1

Many firms required to file either Form CPO-PQR or CTA-PR have reported difficulties in doing so, in most cases due to a lack of guidance. Accordingly, the majority of the NFA’s revisions to the Forms consist of additional or amended “help text.”

The amended Forms CPO-PQR and CTA-PR will become available for the reporting period ending on June 30, 2014. For more information about the revised Forms, please see NFA Notice I-14-13.

1 For more information, please see Sutherland’s February 29, 2012 Legal Alert, “CFTC Issues Rules to Increase Oversight of Funds That Invest in Commodity Interests.”


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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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