The CFTC proposed amending CFTC Rule 4.27 ("Additional reporting by commodity pool operators and commodity trading advisors") and Form CPO-PQR to enhance the integration of collected data on CPO activity.
According to the CFTC, the proposal would update Form CPO-PQR to modify the collection of data from certain registered CPOs and improve agency oversight of CPOs. Specifically, the proposal would:
(i) refocus data collected from CPOs relating to their operated commodity pools and (ii) update Form CPO-PQR to highlight the most useful data;
integrate data sets by adding questions to allow for the conjunctive use of data collected on Form CPO-PQR and other commodity interest market-related data; and
reduce unnecessary filing burdens on registrants by allowing CPOs to submit to NFA's Form PQR instead of the proposed, revised version of the CFTC's Form CPO-PQR.
Chair Heath P. Tarbert stated that the amendments would help in "refining our approach to data collection" in addition to achieving more timely insights into CPO activities.
Commissioner Brian Quintenz supported the proposed elimination of certain questions on Form CPO-PQR, since they require firms to make "numerous underlying assumptions" and ultimately pose challenges for the CFTC in providing direct comparisons across the commodity pool industry.
Commissioner Dan M. Berkovitz supported steps toward improving procedures to aggregate and analyze data by requiring CPOs that engage in swap markets to report legal entity identifiers (or "LEIs").
Commissioner Rostin Behnam expressed concern, despite supporting the proposal overall, that amending Rule 4.27 could result in fewer data being collected on Form PF from CPOs that are dually registered in lieu of only requiring filings of the proposed revised Form CPO-PQR.
Commissioner Dawn D. Stump stated that the proposed revised Form CPO-PQR would be "better distinguished" in its function from Form PF and would reduce complexities.
Comments on the proposal must be submitted within 60 days following the CFTC's April 14, 2020 Open Meeting.
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