CTA Form PR FAQs

In February 2012, the CFTC adopted an annual reporting requirement for all CTAs, including non-Members, under CFTC Regulation 4.27. This report, CFTC Form CTA-PR, became effective for all CTAs starting with the calendar year ending December 31, 2012.

Subsequently, in 2013 NFA amended NFA Compliance Rule 2-46 to require NFA Member CTAs to file a quarterly NFA Form PR in addition to the annual CFTC Form CTA-PR. In general, prior to amending this rule, NFA did not receive much information from CTAs other than their annual update and a Disclosure Document if required. This rule provides NFA with more timely information about our Member CTAs.

The annual CFTC Form CTA-PR and the NFA Form PR are both due within 45 days of the end of the reporting period. The NFA Form PR consists of the CFTC Form CTA-PR plus certain additional information about key relationships, assets under management and monthly performance.

In 2015, the CFTC and NFA both issued relief to inactive CTAs from filing the annual CFTC Form CTA-PR and the quarterly NFA Form PR. NFA sent out a notice to members directing CTAs that qualified for the relief to notify NFA of their inactive status through their CTA Questionnaire by responding “No” to the question whether the firm is directing commodity interest accounts. By doing so, NFA will ensure that its records are accurate and will not expect a filing to be made.

No. Registered CTAs that are inactive or do not direct any commodity interest accounts are not required to file the Form PR with the CFTC. See CFTC Staff Letter No. 15-47 for details.

No. NFA Member CTAs that do not direct commodity interest accounts are not required to file the Form PR with NFA or the CFTC. However, the CTA must notify NFA by responding to the applicable questions in the CTA Questionnaire. See Notice I-15-19 for details on how to notify NFA of the CTA’s inactive status.

NFA Member CTAs that are also registered CPOs that manage only their own pools should answer "Yes" to the question shown below.

Note: If the firm only directs their own pools, all of which are 4.13(a)(3), 12-38 FOF No Action, or 4.5, then the firm can answer "No."

CTA Notices to Members

 

You must first click "Review filing for errors" on the left side of any screen in the filing. If your filing is free of errors, you will get a “Submit Filing” button located at the bottom of the Summary of Error and/or Warnings page. 

form pr summary of errors and/or warnings

Once you submit the filing, you will be asked to complete the oath by entering the capacity in which you are signing on behalf of the CTA. 

cta form pr complete oath screenshot

After completing the oath, you will again click on the “Submit Filing” button and you will receive a confirmation that the filing has been submitted. To ensure the filing has been received, click on the “Filing Index” button at the bottom of the page. 

cta form pr quarterly filing

On the Filing Index page, a date in the “Received Date” column and a status of “Received” will indicate that the filing has been successfully submitted.

cta form pr filing index screenshot

 

The Form PR must be submitted by a representative duly authorized to bind the CTA. This representative will be asked to electronically sign an oath or affirmation prior to submission.

Failure to timely file the NFA Form PR is a violation of NFA Compliance Rule 2-46, and NFA assesses a $200 late fee for each business day the report is filed late. In addition to the late fee, a firm could be subject to disciplinary action should it continue to fail to timely file NFA Form PR. Under Bylaw 1303, failure to pay late fees within 30 days of the due date, will be deemed by NFA as a request by the CTA to withdraw from NFA membership.

From the Filing Index page, click on the specific filing you wish to amend. The system will take you to the “Information About the CTA” page of the specific filing you wish to amend. At the top of the page there is a blue bar that includes a link to "Amend Filing".

cta form pr cta profile screenshot

Once you click on "Amend Filing", a text box will open in which you must include a brief description of the reason for the amendment. Click “Next” when finished. Now you will be able to amend the filing. Once the filing has been amended, you must click on “Submit Filing” to complete the process.

If you are having technical issues, send an email to CTAPRSupport@nfa.futures.org with the following information: firm name, NFA ID, and a detailed description of the problem. An NFA representative will respond to your request within one to two business days.

You may be receiving an error message because you are attempting to re- establish the pool relationship with a start date that is prior to the end date that you previously entered when you terminated the pool relationship. The screen to add the relationship should also indicate the end date that was previously entered.

cta form pr cta pool name screenshot

To re-establish the pool relationship and have it appear on the current filing, add a start date within the current reporting period that is not prior to the previously entered end date.

cta form pr relationship management screenshot

The CPO Form PQR and Form PR are linked through relationships. Therefore, although you may have terminated the relationship with the pools, the respective CPO that operates those pools may have reported a trading manager relationship with your firm which may have re-established a relationship between your firm and the pools.

You can rectify this issue by re-entering an end date in the current reporting period. To alleviate the need to do this every filing, you may also want to contact the CPO to ensure that it is not incorrectly reporting this relationship.

This question is directed at carrying brokers that are registered as an FCM, FDM, and/or RFED that carry your client accounts or that you transact business with as of the reporting date. If your client accounts are solely transacting in swaps and the counterparty is a bank, exempt foreign firm, or swap firm that is provisionally registered, you will not be able to add the firm name unless the counterparty is a CFTC-registered FCM, FDM, or RFED. Leave this information blank and continue completing the filing. Upon submitting the filing, you will receive a warning message directing you to add a carrying broker. A firm can submit a filing with a warning, and the firm has the ability to submit a note if warnings exists.

After the carrying broker name is entered in the search box, a list of carrying brokers will be populated. You must then click “Select” on the left-hand side of the carrying broker’s name. This will take you to another screen that will display the carrying broker’s name and address. You will be asked to enter a start date for the relationship and then click “Add Relationship”. The carrying broker should now be added to Question 3 of the Form PR.

No. The CTA should include any sub-advisor CTAs for which it allocates funds.

Adding a program in Question 6 is a two-step process.

First, click on the Add Program button in the Program Management screen and fill out the program information in the pop-up screen that displays.

cta form pr trading program screenshot

Once the program has been created, you must click on the "Add" link at the left-hand corner of the grid in Question 6. Follow the prompts to add the Once added, it will populate in the grid in all future filings until you remove the program.

cta form pr trading screenshot

To remove a program from the grid, click on the red X at the top-left corner of the grid. A window will open confirming that you want to delete the program. Clicking “yes” will delete the program from the grid. To edit a program in the grid, click on the pencil. This will allow you to enter the rates of return and assets under management each quarter.

cta screenshot

The Assets Directed by the CTA reported in Box 0030 include pool assets attributable to pools for which the CPO is exempt from registration under Regulation 4.13 (exempt pools) and pools for which the CPO is excluded from registration under Regulation 4.5. The assets attributable to these exempt and excluded pools are not included in the amount reported for total assets directed by the CTA in Box 0015. Pool assets attributable to commodity pools that you operate as a CPO and report on the CPO Form PQR should be excluded from the figures reported in both Box 0015 and Box 0030.

As the instructions indicate, the firm should provide a reasonable good-faith estimate when reporting the percentage breakdown of investments in Box 0025, Box 0026, Box 0027 and Box 0028. The breakdown of percentages should be based upon the figure reported in Box 0030.

This bullet point refers to certain investments products where collateral may not be posted as of the reporting date. For purposes of reporting in Question 8, you should report the collateral due but not yet posted in the appropriate investment category. For example, if the collateral is due for a swap transaction, the collateral should be reported in Box 0026 as if posted as of the reporting date.

If the CTA has entered into an agreement with its client(s) to trade account(s) based upon a nominal account size which includes notional funding, the notional funds that make up the nominal value in Box0030 should be reported in "Excess collateral/cash allocated for futures and swap trading" (Box 0027).