On March 20, 2020, in response to the COVID-19 pandemic, the
Division of Swap Dealer and Intermediary Oversight (“CFTC
Staff”) of the U.S. Commodity Futures Trading Commission
(“CFTC”) issued temporary no-action relief to asset
managers who are registered commodity pool operators
(“CPOs”) from certain obligations under the Commodity
Exchange Act and CFTC regulations (the “Relief”). The National Futures
Association (the “NFA”) followed the Relief on March
23, 2020 by issuing Notice to Members I-20-15, which granted similar relief from
rules applicable to member CPOs and commodity trading advisors
(“CTAs”).
Filing Form PQR under CFTC Regulation 4.27:
CFTC Staff has extended the deadline for filing Form PQR for the
year ended December 31, 2019 for small and mid-sized CPOs from the
end of March to May 15, 2020 and for filing Form
PQR for the quarter ending March 31, 2020 for large CPOs from the
end of May until July 15, 2020. The NFA has also
extended the deadline for
