CPO and CTA Filing Requirements

Tracey Hunt, Associate Director, ComplianceMary McHenry, Associate Director, Compliance

Lauren Conway, Citadel Investment GroupSteve Farmer, Mesirow Financial

Pool Quarterly Reports and Form PRForm and Process• CFTC Form• How Help Text is developed

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

CPO’s Approach to Filings• Managing a firm’s regulatory filings• Role of Compliance and other groups/areas• Process• Documenting Assumptions• Reconciliations• Responding to NFA Staff inquiries

Changes to the FormsEffective for June 30th Filings• New questions to obtain information on a firm’s

investments in futures and swaps in terms of an approximate percentage of Total Net AUM• Additional help text, for example• Report assets for pools for which the CPO is required

to be registered (non-exempt pools)• Report actual pool assets (NAV); not notional• Expanded definition of Carrying Broker

Upcoming changes for the September 30th Filings

Common Filing Deficiencies• Relationship start and end dates

• Pools appear on a PQR that should not be filing

• Discrepancies between current and prior filings. For example, NAV or investments

Liquidation Statements• When and where to update NFA’s systems• Impact on PQRs• “Ceased Trading” date• 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

Resources• NFA’s website, www.nfa.futures.org

Form PQR and Form PR templates updated quarterly 2014 Tutorial, ‘Common PQR Filing Deficiencies’

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

CPO and CTA Hot Topics• CPO Delegation

• Third-party Recordkeeping Rules

• Fund-of-Fund Guidance

• Consolidation of Statements

• Recent CFTC Letters

• Exemption/exclusion annual affirmation process