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
- 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
- CFTC Press Release: CFTC Staff Publishes Updated Responses to FAQs regarding Commission Regulation 4.27 and Form CPO-PQR
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.