CFTC – Unanimously Approves a Final Rule Amending Form CPO-PQR

October 6, 2020 – The final rule approved amending form CPO-PQR for commodity pool operators (CPOs). CFTC also amended Rule 4.27 and issued MOU with the office of financial research (OFR).

Form CPO-PQR Updates

Eliminated existing schedules B, C of form, except for pool schedule of investments. Amended data requirements and instructions to request legal entity identifiers (LEIs). LEIs requested for commodity pool operators and their operated pools that have them. Also, amended LEI requirements to delete questions on pool auditors and marketers. Made changes for Schedules B, C rescission, eliminated existing reporting thresholds. The final rule amended CFTC Rule 4.27, 17 CFR 4.27, to permit reporting CPOs to file NFA Form PQR, a comparable form required by NFA, in lieu of filing CFTC’s revised form.


CFTC also announced the approval of an MOU with the Office of Financial Research (OFR). MOU established a framework for CFTC to share data listed on form CPO-PQR with OFR. OFR will use data to carry out its statutory responsibilities and functions, which include conducting financial stability-related research and collecting data on behalf of FSOC.


Final rule and form effective in 30 days from publication in the Federal Register. Reporting CPOs will be required to file a revised form for the quarter ending March 31, 2021. The deadline for filing the revised form for that reporting period is on May 30, 2021.

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