CPO and CTA Filing
Requirements
November 6, 2014
Mary McHenry Associate Director, Compliance
Matt Pendell, Manager, Compliance
Scott Ganis, Partner/COO, Thayer Brook Partners LLP
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

Documenting Assumptions

Reconciliations

Responding to NFA Staff inquiries
Recent Changes to Forms
5
 Effective for June 30th PQR Filings
 Additional help text in Step 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 Step 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 Inquiries
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. For
example, 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
CPO and CTA Hot Topics
20
 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
Resources
21
 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
Thank you