1 / 10

CPO and CTA Filing Requirements Tracey Hunt, Associate Director, Compliance

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

teenie
Download Presentation

CPO and CTA Filing Requirements Tracey Hunt, Associate Director, Compliance

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. CPO and CTA Filing RequirementsTracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance Lauren Conway, Citadel Investment Group Steve Farmer, Mesirow Financial

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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

More Related