CPO and CTA Filing Requirements October 23, 2014 Tracey Hunt, Associate Director, Compliance Mary...

CPO and CTA Filing RequirementsOctober 23, 2014

Tracey Hunt, Associate Director, ComplianceMary McHenry, Associate Director, ComplianceKen Desplaines, Lighthouse Investment PartnersKen Wu, Oppenheimer Funds

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Pool Quarterly Reports and Form PR

Form and Process CFTC Form

Process for making changes

How Help Text is developed

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Pool Quarterly Reports and Form PR

NFA’s review and use of PQRs and PRs Compliance Department Structure Risk Analysis Relationship Data ROR vs. Net Income Conversations between CPO and NFA Staff

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Managing a firm’s regulatory filings

Role of Compliance and other groups/areas

Process

Reconciliations

Documenting assumptions

Responding to NFA Staff inquiries

CPO’s Approach to Filings

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Effective for June 30th PQR Filings Additional help text in Steps 2a and 2b

Recent Changes to Forms

Only include pools for which the CPO is required to be registered

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Effective for June 30th PQR Filings New question: Box 30


Include all commodity pools, even those exempt under 4.13 or excluded under 4.5


•New Questions - Boxes 25-28 - breakdown the total in Box 30

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Effective for June 30th PQR Filings Expanded help text in Step 5


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Effective for June 30th Form PR Filings Additional help text in Step 1d


Include only trading programs for which the CTA is required to be registered

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Effective for June 30th Form PR Filings Additional help text in Steps 2a and 2b


Exclude any assets that are attributable to pools for which the CPO is not required to be registeredExclude any assets that are attributable to pools that you operate as a CPO

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Effective for June 30th PR Filings Additional help text in Step 3


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Effective for June 30th PR Filings New question - Step 8 (Box 30)


Include all managed accounts, even those for commodity pools that are exempt or excluded pursuant to 4.13 or 4.5

Boxes 25-28 breakdown the total in Box 30

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Effective for September 30th PQR Filings Added boxes 8501 and 8502 to Fixed Income section of the

Schedule of Investments


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Effective for September 30th PQR Filings Additional help text was added to Step 10, Statement of AUM

regarding the use of base currencies and conversion factors


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Effective for September 30th PQR Filings Additional relationship information for certain steps will persist

from quarter to quarter


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Relationship start and end dates

Relationships across firms and/or forms

Pools appear on a PQR that should not be filing

Discrepancies between current and prior filings (e.g. NAV or investments)

Responding to NFA Staff inquiries

Common Filing Deficiencies

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Update the Annual Questionnaire to delete or cease a pool, and provide specifics

Liquidation Statements

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“Ceased Trading” date


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Impact on PQRs Disclosure to pool participants Audited by CPA unless waivers are obtained Required components of a liquidation statement Circumstances that do not represent a “liquidated pool”

Switching from 4.7 to 4.13 exempt pool Ceased trading commodity interests Temporary cessation of trading

Other regulatory requirements other than CFTC


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NFA’s website, www.nfa.futures.org Form PQR and Form PR templates updated quarterly 2014 Tutorial, “Common PQR Filing Deficiencies” 2013 Webinar, “Quarterly Reporting Requirements for CTAs”

Technical Support [email protected] [email protected]

NFA’s Information Center (800) 621-3570, or (312) 781-1410

Resources

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CPO delegation

Third-party recordkeeping rules

Fund-of-Fund guidance

Consolidation of statements

Exemption/exclusion annual affirmation process

Possible CPO and CTA customer protection measures

CPO and CTA Hot Topics

Thank you.

CPO and CTA Filing Requirements October 23, 2014 Tracey Hunt, Associate Director, Compliance Mary...

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