CFTC – Final Rule – Compliance Requirements for Commodity Pool Operators

November 10, 2020 – The CFTC is adopting amendments to the Final Rule to regulations on additional reporting by commodity pool operators (CPOs) and commodity trading advisors and to Form CPO-PQR.

The CFTC is eliminating existing Schedules B and C of Form CPO-PQR, except for the Pool Schedule of Investments; amending the information requirements and instructions to request Legal Entity Identifiers (LEIs) for CPOs and their operated pools that have them, and to delete questions regarding pool auditors and marketers.

Additionally, making certain other changes due to the rescission of Schedules B and C, including the elimination of all existing reporting thresholds. Pursuant to the Final Rule, all reporting CPOs will be required to file the revised Form CPO-PQR quarterly. The Final Rule also amends Commission regulations to permit reporting CPOs to file NFA Form PQR, a comparable form required by the National Futures Association (NFA), in lieu of filing the Revised Form.

Conversely, Form PF will no longer be accepted in lieu of the Revised Form, though it will remain a Commission form.

Effective Date

The effective date for the Final Rule, including the adoption of the Revised Form, is December 10, 2020.

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