CFTC Provides Welcome Relief By Streamlining Form CPO-PQR

On October 6, 2020 the CFTC approved a final rule amending the reporting requirements for registered commodity pool operators ("CPOs") on Form CPO-PQR (the "Final Rule"). The Final Rule simplifies and streamlines the CPO reporting process while continuing to obtain necessary data. After seven years of experience with Form CPO-PQR, the CFTC found that it was unable to use much of the information required, and that some information it needed was available from other sources.

As discussed in more detail in our prior release ( here), the Final Rule aligns the substantive and filing requirements of CFTC Form CPO-PQR with the NFA's version of Form PQR,¹ which registered CPOs also currently file. Once the Final Rule is effective, all CPOs will be able to file a single version of Form PQR. In addition, the Final Rule eliminates the reporting threshold concept so that all registered CPOs will file on a quarterly basis (as is already required by the NFA).