CFTC Releases FAQs Regarding CFTC Forms CPO-PQR and CTA-PR
Commentary by Dorothy Mehta
The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") published responses to frequently asked questions ("FAQs") concerning CFTC Forms CPO-PQR and CTA-PR.
The FAQs address issues ranging from Form CPO-PQR and Form CTA-PR filing mechanics and deadlines to technical questions regarding asset reporting classification.
DSIO staff intends to update the FAQs on an as-needed basis in order to clarify issues for the broadest range of filers.
Commentary
The FAQs provide much-needed guidance on a wide range of questions. Firms should carefully consider the application of the FAQs to their fund structures, including to master-feeder fund structures, parallel pools and managed accounts, and offshore pools and pools operated pursuant to CFTC exemptions to Rules 4.5, 4.7 and 4.13(a)(3) and Advisory 18-96, among others. They also should consider the application of the FAQs to their filing requirements, if they are duly registered as investment advisers with the SEC.