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September 16, 2013
New Quarterly Filing Requirements for CTAs under NFA Compliance Rule 2-46 to Commence with Quarter Ending September 30, 2013
In 2012, the CFTC adopted Regulation 4.27 which, among other things, requires that all CTAs file a Form PR annual report with the CFTC within 45 days of the calendar year end. The Form PR requires each CTA to report on an annual basis general information about the CTA, its trading programs, the pool assets directed by the CTA and the identity of the CPOs that operate those pools. This annual requirement became effective for calendar year ending December 31, 2012.
As indicated in Notice I-13-02, NFA had proposed to amend Compliance Rule 2-46 to require CTAs report to NFA on a quarterly basis and the CFTC approved those amendments on March 30, 2013. The first filing for NFA Member CTAs will be for the quarter ending September 30, 2013 and will be due on November 14, 2013. NFA's quarterly Form PR consists of the CFTC annual Form PR along with some additional questions relating to certain trading programs being offered by the CTA, and the related monthly rates of return and the assets under management for those trading programs. See here for a sample PR report.
All CTA Members, regardless of whether they are currently active, must submit a Form PR each quarter. The NFA Form PR filing as of December 31 will satisfy the CFTC requirement as well. All filings for both NFA and the CFTC will be submitted through NFA's EasyFile system, at the following link: http://www.nfa.futures.org/NFA-electronic-filings/easyFile-CTA-filers.HTML. In order to access the EasyFile system, the CTA's security manager must set up the necessary security settings. Instructions on how to do that can be found on our website. NFA plans to provide a webinar on this new filing and will provide further information later this month.
As a reminder, please note that EasyFile requires a currently supported version of Microsoft Internet Explorer or Firefox. Questions concerning the reporting requirements should be directed to Susan Koprowski, Senior Manager, Compliance (firstname.lastname@example.org or 312-781-1288) or Christine Roche, Senior Manager, Compliance (email@example.com or 312-781-1562).