In response to the COVID-19 pandemic’s potential impact on firms, the SEC has come forward with several contingency and relief measures in an effort to ease the regulatory burdens that investment advisors and stakeholders may be facing in the new all-remote work environment.
During the earlier days of the pandemic, the SEC announced that they were extending filing deadlines for a number of regulatory obligations including Form ADV, Form PF and Brochure Delivery. Now, both the SEC and NFA continue to monitor how the market is functioning as well as impending risks that may be lingering in this new environment in order to be able to provide swift guidance and relief to impacted parties if needed while still maintaining continuity of operations.
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