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CPO and CTA Filing Requirements Tracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance Lauren Conway, Citadel Investment Group Steve Farmer, Mesirow Financial. Pool Quarterly Reports and Form PR . Form and Process CFTC Form How Help Text is developed
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CPO and CTA Filing RequirementsTracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance Lauren Conway, Citadel Investment Group Steve Farmer, Mesirow Financial
Pool Quarterly Reports and Form PR • Form 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 Forms • Effective 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