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ARTICLE · 01 JUNE 2021

CFTC Updates FAQs On Form CPO-PQR

Hogan Lovells Cadwalader
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The CFTC's Market Participants Division updated its 2015 FAQs regarding CFTC Rule 4.27 and Form CPO-PQR to reflect the October 2020 adoption of amendments to both the rule and the form.

United StatesFinance and Banking
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The CFTC's Market Participants Division updated its 2015 FAQs regarding CFTC Rule 4.27 ("Additional Reporting by Commodity Pool Operators and Commodity Trading Advisors") and Form CPO-PQR to reflect the October 2020 adoption of amendments to both the rule and the form.

The FAQs clarified, among other things:

  • who is required to complete and file Form CPO-PQR;
  • whether all commodity pool operators ("CPOs") for a pool operated by two or more CPOs must file Form CPO-PQR;
  • whether a CPO can file Form PF with the CFTC in lieu of Form CPO-PQR;
  • the reporting requirements on Form CPO-PQR and NFA Form PQR for pools exempt from registration under CFTC Rule 4.13(a)(3);
  • whether a registered CPO operating offshore pools pursuant to CFTC Advisory 18-96 must file Form CPO-PQR for those offshore pools; and

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