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First Filing of Form NFA-PQR for CPOs and Form NFA-PR for CTAs

Quarterly Form NFA-PQR for registered CPOs

The first Form NFA-PQR for newly-registered CPOs whose registration became effective on January 1, 2013 is due sixty days from calendar-quarter end, i.e. by May 31, 2013 for the quarter ended March 31, 2013. Form NFA-PQR is filed every quarter by all registered CPOs. The NFA Form PRQ is distinct from the CFTC Form CPO-PQR which must be filed on a quarterly or annual basis depending on the assets under management (“AUM”) of the firm.

On April 24, the NFA issued an interpretative notice explaining the following:

  • Large CPOs (i.e. CPOs with at least $1.5 billion in pool AUM) who are required to file CFTC Form CPO-PQR (Schedules A, B and C) on a quarterly basis with the CFTC within 60 days of the quarter end will only file CFTC Form CPO-PQR and that filing will satisfy their NFA filing requirement as well. No separate filing of Form NFA-PQR is required.
  • Mid-size CPOs (i.e. CPOs with AUM between $150 million and $1.5 billion) which have an annual and not a quarterly CFTC filing requirement will continue to be required to file NFA Form PQR for the quarters ending March, June and September, within 60 days of the quarter end. Mid-size CPOs will satisfy the December 31 NFA quarterly filing requirement by filing the annual CFTC Form PQR (Schedules A and B) within 90 days of the close of each calendar year end. The December 31 filing will satisfy the requirement of both CFTC Form CPO-PQR and NFA Form PQR. No separate filing of Form NFA-PQR will be required for the fourth quarter.
  • Small CPOs (i.e. CPOs with less than $150 million AUM) which also have an annual and not a quarterly CFTC filing requirement will continue to be required to file NFA Form PQR for the quarters ended March, June and September within 60 days of the quarter end. Small CPOs will satisfy the December 31 NFA quarterly requirement by filing CFTC Form PQR (Schedule A) plus a Schedule of Investments within 90 days of the close of each calendar year end. The December 31 filing will satisfy the requirements of both CFTC Form PQR and NFA Form PQR. No separate filing of Form NFA PQR will be required for the fourth quarter.
  • CPOs that file Form PF with the SEC in lieu of CFTC Form PQR because they are also SEC registered advisers will be required to file NFA Form PQR with NFA on a quarterly basis within 60 days of the quarter end, except for the quarter ending December 31. For that quarter, the CPO/registered investment adviser can satisfy NFA's quarterly requirement by filing CFTC Form PQR (only Schedule A because all other Schedules are substituted by the filing of Form PF) plus a Schedule of Investments within 60 or 90 days, depending on the size of the CPO. No separate filing of Form NFA PQR will be required for the forth quarter.

Quarterly Form NFA-PR for registered CTAs

All registered CTAs must file a quarterly Form NFA-PR within forty-five days from quarter end. This is a new quarterly filing requirement and NFA has not finalized the date of the first required filing. NFA will advise CTA Members of the date of the first quarterly report and provide filing information and instructions well in advance of that date. The NFA announced in its April 24 guidance that no quarterly filing will be due for the quarters ended March 31 or June 30, 2013.

The recent NFA guidance on Forms NFA-PQR and NFA-PR is  available online. For the filing requirements of the different types of CPOs and the calculation of pool AUM, please review our previous communiqué titled Filing Dates for Form CPO-PQR and Guidelines for Calculating Assets under Management"

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Events

May 23, 2017 - Webcast: WannaCry Ransomware: Were You Really Protected or Just L…

When: Tuesday, May 23rd, 2017 | Schedule: 12pm - 1pm EST Who: Paul Caiazzo, CEO and Co-Founder, TruShield Security Solutions Michael Brice, Founder, BW Cyber Services John Lukan, Managing Director, SEC Compliance Consultants, Inc. We...

June 14, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Willkie Farr & Gallagher LLP | 600 Travis Street | Suite 2310 | Houston, TX Barry Barbash from Willkie Farr & Gallagher LLP,...

June 13, 2017 - Compliance Breakfast Briefing

8:30-9:00am - Networking and Continental Breakfast 9:00-10:30am - Program Location: Haynes and Boone, LLP | 2323 Victory Avenue | Suite 700 | Dallas, TX 75219 Validated parking is available in the garage attached...

May 31, 2017 - Chicago

9:00-9:30 a.m - Networking and Continental Breakfast 9:30-11:00 a.m - Program Location: Baker & McKenzie LLP | 300 East Randolph Drive | Suite 5000 | Chicago, IL 60601 Kristin Gonzalez and Jerome Tomas...

May 17, 2017 (NYC WIMF)

This event is by invitation only. Please email info@seccc.com to learn more.

May 15, 2017 (NYC Chief Compliance Officer Roundtable)

9:00-9:30am - Networking and Continental Breakfast 9:30-11:00am - Program Location: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 | 22nd Floor Boardroom | Phone:...

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In this webinar, panelists discuss indemnifications and insurance as potential remedies to address the direct financial risks to a CCO. Attendees will learn: What terms and conditions should Chief Compliance Officers be...

Webinar: CCO Liability (Part III): Managing Liability: Navigating Indemnities an…

When: Tuesday, February 21, 2017 Schedule: 11:00am ET / 10:00am CT / 9:00am MT / 8:00am PT / 7:00am AT Description of Webinar: The National Society of Compliance Professionals is pleased to host...

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When: April 13, 2016 Where: Blank Rome LLP | The Chrysler Building | 405 Lexington Avenue | New York, NY 10174 22nd Floor Boardroom Thomas Westle and Janaya Moscony, along with industry experts,...

COMPLIANCE SCIENCE SUMMIT 2015

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