CPO and CTA Filing
Requirements
October 23, 2014
Tracey Hunt, Associate Director, Compliance
Mary McHenry, Associate Director, Compliance
Ken Desplaines, Lighthouse Investment Partners
Ken Wu, Oppenheimer Funds
Pool Quarterly Reports and Form PR
2
 Form and Process
 CFTC Form

Process for making changes

How Help Text is developed
Pool Quarterly Reports and Form PR
3
 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
CPO’s Approach to Filings
4

Managing a firm’s regulatory filings

Role of Compliance and other groups/areas

Process

Reconciliations

Documenting assumptions

Responding to NFA Staff inquiries
Recent Changes to Forms
5
 Effective for June 30th PQR Filings
 Additional help text in Steps 2a and 2b
 Only include pools for which the CPO is required to be registered
Recent Changes to Forms
6
 Effective for June 30th PQR Filings
 New question: Box 30
 Include all commodity pools, even those exempt under 4.13 or excluded
under 4.5
Recent Changes to Forms
•New Questions - Boxes 25-28 - breakdown the total in Box 30
Recent Changes to Forms
8
 Effective for June 30th PQR Filings
 Expanded help text in Step 5
Recent Changes to Forms
9
 Effective for June 30th Form PR Filings
 Additional help text in Step 1d
 Include only trading programs for which the CTA is required to be registered
Recent Changes to Forms
10
 Effective for June 30th Form PR Filings
 Additional help text in Steps 2a and 2b
Exclude any assets that are attributable to pools for which the CPO is not required to be
registered
Exclude any assets that are attributable to pools that you operate as a CPO
Recent Changes to Forms
11
 Effective for June 30th PR Filings
 Additional help text in Step 3
Recent Changes to Forms
12
 Effective for June 30th PR Filings
 New question - Step 8 (Box 30)
 Include all managed accounts, even those for commodity pools that are
exempt or excluded pursuant to 4.13 or 4.5
 Boxes 25-28 breakdown the total in Box 30
Recent Changes to Forms
13
 Effective for September 30th PQR Filings
 Added boxes 8501 and 8502 to Fixed Income section of the Schedule of
Investments
Recent Changes to Forms
14
 Effective for September 30th PQR Filings
 Additional help text was added to Step 10, Statement of AUM regarding the
use of base currencies and conversion factors
Recent Changes to Forms
15
 Effective for September 30th PQR Filings
 Additional relationship information for certain steps will persist from quarter to
quarter
Common Filing Deficiencies
16
 Relationship start and end dates
 Relationships across firms and/or forms
 Pools appear on a PQR that should not be filing
 Discrepancies between current and prior filings (e.g. NAV or
investments)
 Responding to NFA Staff inquiries
Liquidation Statements
17
 Update the Annual Questionnaire to delete or cease a pool, and provide
specifics
Liquidation Statements
18
 “Ceased Trading” date
Liquidation Statements
19
 Impact on PQRs
 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
Resources
20
 NFA’s website, www.nfa.futures.org
 Form PQR and Form PR templates updated quarterly
 2014 Tutorial, “Common PQR Filing Deficiencies”
 2013 Webinar, “Quarterly Reporting Requirements for CTAs”
 Technical Support
 PQRsupport@nfa.futures.org
 PRsupport@nfa.futures.org
 NFA’s Information Center
 (800) 621-3570, or
 (312) 781-1410
CPO and CTA Hot Topics
21
 CPO delegation
 Third-party recordkeeping rules
 Fund-of-Fund guidance
 Consolidation of statements
 Exemption/exclusion annual affirmation process

Possible CPO and CTA customer protection measures
Thank you.