NFA Amends Compliance Rule on CPO and CTA Quarterly Reporting Requirements

The NFA has amended its quarterly reporting requirements for CPOs under Compliance Rule 2-46, and has adopted new quarterly reporting requirements for CTAs under that Rule (although it has deferred implementation of the new CTA requirements).

Amendments to Quarterly Reporting Requirements for CPOs:

While NFA will continue to require all CPOs to file Form PQR reports on a quarterly basis, the amendments harmonize the NFA's reporting requirements with the CFTC's Form CPO-PQR reporting requirements under CFTC Rule 4.27 in several important respects:

First, where a CPO is required to file CFTC Form CPO-PQR for the relevant quarter (including the year-end), the firm generally will be deemed to have met its quarterly reporting requirement under NFA Rule 2-46 by filing the relevant schedules of Form CPO-PQR (though in certain cases the firm will also be required to file an NFA Schedule of Investments).

Second, the NFA has aligned its reporting deadlines with those under CFTC Rule 4.27. Thus, reports for the March, June and September quarters will be due within 60 days of the calendar quarter (currently they are due within 45 days). Reports for the quarter ending December 31st will be due within 60 or 90 days, depending on the CPO's reporting deadline under Rule 4.27.

Third, the NFA has amended Form PQR to be "more comparable" with CFTC Form CPO-PQR. One consequence of this is that the threshold for itemization of investments in the Schedule of Investments has been lowered from 10 percent of NAV to 5 percent.

New Quarterly Reporting Requirements for CTAs

The NFA has adopted amendments to NFA Compliance Rule 2-46 to require CTAs to file quarterly reports on NFA Form PR. However, the NFA will not require CTAs to file these reports for at least the first two quarters of 2013. The NFA stated that it will advise CTAs of the date of the first quarterly report, and provide filing information and instructions "well in advance of that date."

Click here to view Notice to Members in full (links externally to NFA website).

See also: Lofchie Guide to CPO-CTA Regulation: Disclosure, Reporting and Recordkeeping.See also: CPO/CTA Materials on the Cabinet (advertisement for the Cabinet).