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October 01, 2014
Notice to CPOs regarding changes to the CPO Form PQR and an important compliance reminder to CPOs and CTAs to ensure that Forms PQR and PR and pool Annual Reports are filed in a timely manner
Changes to the CPO Form PQR
Based on feedback and questions NFA received from CPO Members, NFA has made minor changes to the CPO Form PQR (Click here to access a PDF detailing the changes to the Form PQR). These changes become effective for the quarter ending September 30, 2014. The updated Form PQR will be available in the EasyFile system on October 6, 2014, along with an updated PQR template with expanded help text. For CPO PQR XML filers, an updated schema is also available for upload in the XML Documentation section of EasyFile. Please note that since the schema files have changed, CPO Members will need to update the system that is used to generate XML documents because certain box numbers have been added or eliminated. NFA recommends that XML filers forward this Notice to the firm's technical team. There are no changes to the CTA Form PR this quarter.
Recent Business Conduct Committee Actions Charging Violations of NFA Compliance Rule 2-46
As a reminder, NFA Compliance Rule 2-46 requires NFA Member CPOs and CTAs to electronically file Forms PQR and PR (as applicable) with NFA on a quarterly basis. PQR filings are due within 60 days of the quarters ending in March, June and September and within 90 days of the December quarter end. PR filings are due within 45 days of each quarter end. In addition, NFA Compliance Rule 2-13 requires CPO Members to file a copy of the Annual Report it prepares for each pool that it operates with NFA within 90 days of the pool's fiscal year end. These reports provide NFA with valuable information, which NFA integrates into NFA's compliance risk management system to monitor Member operations. Despite the importance of this information, each reporting period a number of Members fail to file these reports in a timely manner. Members should be aware that failing to timely file these reports is a violation of NFA Rules and may subject the Member to disciplinary action. In fact, in September 2014, NFA's Business Conduct Committee issued Complaints against two firms charging violations of NFA Compliance Rule 2-46. The details of these Complaints can be found by accessing the following link: http://www.nfa.futures.org/news/newsActionsList.asp.
Questions concerning these reporting requirements should be directed to Tracey Hunt, Associate Director, Compliance (firstname.lastname@example.org or 312-781-1284) or Mary McHenry, Associate Director, Compliance (email@example.com or 312-781-1420).