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Valuable Insights on CPO-PQR Reporting

Commodity  Pool Operators (CPOs) are required to file information regarding their firm and pools operations as mandated by the Commodities and Futures Trading Commission (CFTC) and the National Futures Association (NFA).

The size of the CPO determines whether filing is required by the CFTC or NFA and Form CPO-PQR is a single filing to accommodate both regulators.

This filing requires CPOs to provide manager, portfolio, performance and risk information about their funds which includes investment strategy, asset classes, risk metrics, collateral, counterparty credit exposure and many more aspects of operating the pool.

1 – Types of firms affected and why

  • ​Individual advisors and organizations registered as Commodity Pool Operators (CPOs) with the CFTC
  • Filing introduced due to increased jurisdiction from the CFTC to supervise swaps (i.e. credit, commodities and interest rate)
  • Newly registered CPOs need to understand whether or not they are exempt from filing. Exempt CPOs include:

a. Those otherwise regulated, such as a bank, insurance company or a registered investment company

b. Those who operate one or more small pool(s) that have received less than $400,000 in aggregate capital contributions and that have no more than 15 participants in any one pool

c.Those who operate pools that do not commit more than 10 percent of the fair market value of their assets to establish commodity interest trading positions

2 – When and which sections should a firm file?

3 – How European firms may or may not be affected

European firms that have a subsidiary in the U.S. registered with the CFTC or those who do commodity trading must file

4 – In terms of differences and similarities, what is the relationship of this form as compared to Form PF?



5 – How can Form PF data be leveraged?

Form PF preparation can be further leveraged for the following questions:

​Other additional details:

Static data details:

Please Refer to the CPO-PQR reporting template here

IVP Regulatory Reporting Solution 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 CPO/PQR, thereby saving time and effort, and making the solution less complex and more cost-effective. For details, contact us at


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