CPO Members—Changes to the NFA Form PQR

NFA Compliance Rule 2-46 requires, with limited exceptions, commodity pool operator (CPO) Members to file NFA Form PQR on a quarterly basis with NFA for each pool that it operates. CFTC Regulation 4.27 imposes similar CPO reporting requirements by requiring CPOs to file CFTC Form CPO-PQR.

Guidance on the annual affirmation requirement for entities currently operating under an exemption from CPO or CTA registration

The CFTC requires any person that claims an exemption from CPO registration under CFTC Regulation 4.13(a)(1), 4.13(a)(2), 4.13(a)(3), 4.13(a)(5), an exclusion from CPO registration under CFTC Regulation 4.5 or an exemption from CTA registration under 4.14(a)(8) (collectively, exemption) to annually affirm the applicable notice of exemption within 60 days of the calendar year end, which is March 1, 2021 for this affirmation cycle.

CFTC/NFA Members Victims of Corporate Identity Theft

Based on the increasing amount of corporate identity theft, every registered firm, regardless of whether they are actively trading or soliciting, should be conducting regular web searches based on the company’s name. Turnkey has witnessed firms, with and without websites, come under NFA scrutiny over an URL they have no relation to.