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CPO and CTA Filing Requirements

CPO and CTA Filing Requirements. October 23, 2014. Tracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance Ken Desplaines , Lighthouse Investment Partners Ken Wu, Oppenheimer Funds. Pool Quarterly Reports and Form PR. Form and Process CFTC Form

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CPO and CTA Filing Requirements

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  1. CPO and CTA Filing Requirements October 23, 2014 Tracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance Ken Desplaines, Lighthouse Investment Partners Ken Wu, Oppenheimer Funds

  2. Pool Quarterly Reports and Form PR • Form and Process • CFTC Form • Process for making changes • How Help Text is developed

  3. 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

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

  5. Recent Changes to Forms • Effective for June 30th PQR Filings • Additional help text in Steps 2a and 2b • Only include pools for which the CPO is required to be registered

  6. Recent Changes to Forms • 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

  7. Recent Changes to Forms • New Questions - Boxes 25-28 - breakdown the total in Box 30

  8. Recent Changes to Forms • Effective for June 30th PQR Filings • Expanded help text in Step 5

  9. Recent Changes to Forms • 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

  10. Recent Changes to Forms • 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 registered • Exclude any assets that are attributable to pools that you operate as a CPO

  11. Recent Changes to Forms • Effective for June 30th PR Filings • Additional help text in Step 3

  12. Recent Changes to Forms • 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

  13. Recent Changes to Forms • Effective for September 30th PQR Filings • Added boxes 8501 and 8502 to Fixed Income section of the Schedule of Investments

  14. Recent Changes to Forms • 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

  15. Recent Changes to Forms • Effective for September 30th PQR Filings • Additional relationship information for certain steps will persist from quarter to quarter

  16. Common Filing Deficiencies • 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

  17. Liquidation Statements • Update the Annual Questionnaire to delete or cease a pool, and provide specifics

  18. Liquidation Statements • “Ceased Trading” date

  19. Liquidation Statements • 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

  20. Resources • 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 • PQRsupport@nfa.futures.org • PRsupport@nfa.futures.org • NFA’s Information Center • (800) 621-3570, or • (312) 781-1410

  21. CPO and CTA Hot Topics • 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

  22. Thank you.

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