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1 June 2021

CFTC Updates FAQs On Form CPO-PQR

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Cadwalader, Wickersham & Taft LLP

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The CFTC's Market Participants Division updated its 2015 FAQs regarding CFTC Rule 4.27 and Form CPO-PQR to reflect the October 2020 adoption of amendments to both the rule and the form.
United States Finance and Banking

The CFTC's Market Participants Division updated its 2015 FAQs regarding CFTC Rule 4.27 ("Additional Reporting by Commodity Pool Operators and Commodity Trading Advisors") and Form CPO-PQR to reflect the October 2020 adoption of amendments to both the rule and the form.

The FAQs clarified, among other things:

  • who is required to complete and file Form CPO-PQR;
  • whether all commodity pool operators ("CPOs") for a pool operated by two or more CPOs must file Form CPO-PQR;
  • whether a CPO can file Form PF with the CFTC in lieu of Form CPO-PQR;
  • the reporting requirements on Form CPO-PQR and NFA Form PQR for pools exempt from registration under CFTC Rule 4.13(a)(3);
  • whether a registered CPO operating offshore pools pursuant to CFTC Advisory 18-96 must file Form CPO-PQR for those offshore pools; and
  • the answers to frequently asked questions regarding specific Form CPO-PQR requirements.

Primary Sources

  1.  CFTC FAQs: CFTC's Market Participants Division Publishes Updated Responses to Frequently Asked Questions ("FAQs") regarding Commission Regulation 4.27 and CFTC Form CPO-PQR
  2. CFTC Press Release: CFTC Staff Publishes Updated Responses to FAQs regarding Commission Regulation 4.27 and Form CPO-PQR

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