Notices to Members

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Notice I-21-21

July 01, 2021

Amendments to NFA Compliance Rule 2-46 conforming CPO filing requirements to CFTC Regulation 4.27 now effective

NFA Compliance Rule 2-46 requires, with limited exceptions, commodity pool operator (CPO) Members to file NFA Form PQR on a quarterly basis with NFA for each pool that it operates. CFTC Regulation 4.27 imposes similar CPO reporting requirements by requiring CPOs to file CFTC Form CPO-PQR.

In October 2020, the CFTC adopted several amendments to CFTC Regulation 4.27 to, among other things:

  • Adopt a uniform quarterly reporting schedule for CFTC Form CPO-PQR for all CPOs;
  • Streamline the form to make it more consistent with NFA Form PQR; and
  • Permit CPOs to file NFA Form PQR in lieu of the revised CFTC Form CPO-PQR.

To maintain consistency with the CFTC's amendments, NFA has amended Compliance Rule 2-46 to:

  • Require CPO Members to file NFA Form PQR within 60 days of each calendar quarter end, including the December 31 filing which was previously due within 90 days; and
  • Eliminate the provision that permits certain CPOs to satisfy their Compliance Rule 2-46 reporting requirements by filing CFTC Form CPO-PQR.

These amendments became effective on June 11, 2021.

NFA's CPO/CTA Advisory Committee supported the amendments to Compliance Rule 2-46, which were unanimously approved by the Board.

More information on the amendments can be found in NFA's June 1, 2021 submission letter to the CFTC. If you have any questions, please contact Dawn Grossmith, Senior Manager, Financial Analysis and Surveillance, Compliance ( or 212-513-6012).

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