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ARTICLE · 08 JULY 2021

NFA Form PQR Amendments Are Now Effective

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NFA amendments to Compliance Rule 2-46 ("CPO and CTA Quarterly Reporting Requirements") went into effect on June 11, 2021.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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NFA amendments to Compliance Rule 2-46 ("CPO and CTA Quarterly Reporting Requirements") went into effect on June 11, 2021. The amendments conform NFA Form PQR filing requirements to those of CFTC Form CPO-PQR.

In October 2020, the CFTC finalized amendments to Rule 4.27 ("Additional Reporting by Commodity Pool Operators and Commodity Trading Advisors"), which, among other things, (i) required reporting CPOs to file the revised Form CPO-PQR quarterly and (ii) allowed CPOs to submit NFA Form PQR instead of the revised Form CPO-PQR, but eliminated the ability of CPOs to submit Form PF in lieu of Form CPO-PQR.

NFA amended Compliance Rule 2-46 to (i) require CPOs to file NFA Form PQR within 60 days of each calendar quarter end and (ii) eliminate the provision that allowed CPOs to satisfy reporting requirements under Compliance Rule 2-46 by filing CFTC Form CPO-PQR.

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