CFTC Updates FAQs on Form CPO-PQR

The CFTC's Market Participants Division updated its 2015 FAQs regarding CFTC Rule 4.27 ("Additional Reporting by Commodity Pool Operators and Commodity Trading Advisors") and Form CPO-PQR to reflect the October 2020 adoption of amendments to both the rule and the form.

The FAQs clarified, among other things:

  • who is required to complete and file Form CPO-PQR;

  • whether all commodity pool operators ("CPOs") for a pool operated by two or more CPOs must file Form CPO-PQR;

  • whether a CPO can file Form PF with the CFTC in lieu of Form CPO-PQR;

  • the reporting requirements on Form CPO-PQR and NFA Form PQR for pools exempt from registration under CFTC Rule 4.13(a)(3);

  • whether a registered CPO operating offshore pools pursuant to CFTC Advisory 18-96 must file Form CPO-PQR for those offshore pools; and

  • the answers to frequently asked questions regarding specific Form CPO-PQR requirements.

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