Tracey Hunt, Associate Director, Compliance
Mary McHenry, Associate Director, Compliance
Lauren Conway, Citadel Investment Group
Steve Farmer, Mesirow Financial

Form and Process
• CFTC Form
• How Help Text is developed
NFA’s review and use of PQRs and PRs
• Compliance Department Structure
• Risk Analysis
• Relationship Data
• ROR vs. Net Income
• Conversations between CPO and NFA Staff

• Managing a firm’s regulatory filings
• Role of Compliance and other groups/areas
• Process
• Documenting Assumptions
• Reconciliations
• Responding to NFA Staff inquiries

Effective for June 30 th Filings
• New questions to obtain information on a firm’s investments in futures and swaps in terms of an approximate percentage of Total Net AUM
• Additional help text, for example
• Report assets for pools for which the CPO is required to be registered (non-exempt pools)
• Report actual pool assets (NAV); not notional
• Expanded definition of Carrying Broker
Upcoming changes for the September 30th Filings

• Relationship start and end dates
• Pools appear on a PQR that should not be filing
• Discrepancies between current and prior filings.
For example, NAV or investments

• When and where to update NFA’s systems
• Impact on PQRs
• “Ceased Trading” date
• Disclosure to Pool Participants
• Audited by CPA unless waivers are obtained
• Required components of a liquidation statement
• Circumstances that do not represent a “liquidated pool”
• Switching from 4.7 to 4.13 exempt pool
• Ceased trading commodity interests
• Temporary cessation of trading
• Other regulatory requirements other than CFTC

• NFA’s website, www.nfa.futures.org
 Form PQR and Form PR templates updated quarterly
 2014 Tutorial, ‘Common PQR Filing Deficiencies’
• NFA’s Information Center
(800) 621-3570, or
(312) 781-1410

• CPO Delegation
• Third-party Recordkeeping Rules
• Fund-of-Fund Guidance
• Consolidation of Statements
• Recent CFTC Letters
• Exemption/exclusion annual affirmation process