Latest Amendments to Form CPO-PQR by the Commodity Futures Trading Commission (CFTC)

To reduce reporting burdens and enhance the oversight capabilities of commodity pool operators (CPOs) by making use of alternative data sources, the Commodity Futures Trading Commission (CFTC) had adopted amendments to Form CPO-PQR and CFTC Rule 4.27 on October 6^th, 2020.

Summary of Changes:

1. Schedule B and C of Form CPO-PQR to be eliminated, except for the Pool Schedule of Investments (Schedule B – Q6-PSOI).
2. Schedule A to no longer have questions regarding a pool’s auditors and marketers. However, legal entity identifiers (LEIs) will be required for CPOs and their pools.
3. Reporting CPOs must submit all information in the revised format on a quarterly basis, regardless of assets under management.
4. CPOs are allowed to file the National Futures Association (NFA) Form PQR in lieu of the revised CFTC Form CPO-PQR, provided that it amends Form PQR to include LEIs.
5. Substituted compliance via Joint Form PF is to be eliminated. CFTC Rule 4.27(d) is amended to disallow dually registered CPOs to file Joint Form PF in lieu of Schedules B and C with respect to commodity pools that are not private funds. As per the client memo: “This does not change Joint Form PF’s status as the Commission’s form, nor does it change the requirement that dually registered CPOs and investment advisers continue to file Joint Form PF with the SEC.”

*Refer to the full client memo here.

The CFTC will soon be coming up with updated instructions to the revised Form CPO-PQR along with an updated  document of “Frequently Asked Questions” to provide all the assistance CPOs need to complete and correctly file the revised version of this form.

As per the client memo published on October 15th, 2020: “The final rule is the first of several steps in the Commission’s ongoing reassessment of Form CPO-PQR and will become effective 30 days following the date of publication in the Federal Register.
As per NFA’s email notification, all reporting CPOs will be required to report on the revised Form CPO-PQR with respect to their pools for the calendar quarter ending December 31, 2020 by March 31, 2021.” The updated question reporting list published by NFA can be accessed by clicking here.

IVP Regulatory Reporting , has been filing on behalf of more than 50 CPO-PQR clients for over five years. It leverages reporting information common to Form PF for Form CPO-PQR, therefore saving time and effort, and making the solution less complex and more cost effective.

To learn more about these mandates and gain valuable insights on Form CPO-PQR reporting, read our in-depth analysis HERE.

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