In amending the CPO/CTA registration rules in February of 2012, the CFTC amended CFTC Rule 4.27 to require registered CTAs and CPOs to report information and data to the CFTC on Forms CTA-PR and CPO-PQR. In addition NFA rule 2-46 requires those with reporting obligations under CFTC Rule 4.27 to report Form NFA-PQR. The CFTC however delayed these reporting requirements for 1940 Act registered investment companies ("RICs") until 60 days after the publication of its CPO/SEC harmonization rules.

With the completion and publication of the harmonization rules, the Form CPO-PQR reporting obligations for CPOs of RICs will apply on Monday, October 21, 2013.

The filing dates for CPOs depend on the size of the CPO's pool assets under management ("Pool AUM") measured as of the close of business on any day during a quarter/year.

Pool AUM

CPO-PQR Filing Dates

NFA-PQR Filing Dates

$1.5 billion or greater

60 days after the close of each calendar quarter

(satisfied by filing CPO-PQR)

Less than $1.5 billion

90 days after the close of each calendar year

60 days after the close of each calendar quarter

 Good day. Good reporting. TSR

This article is presented for informational purposes only and is not intended to constitute legal advice.