cpo and cta filing requirements november 6, 2014 mary mchenry associate director, compliance matt...
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CPO and CTA Filing RequirementsNovember 6, 2014
Mary McHenry Associate Director, ComplianceMatt Pendell, Manager, ComplianceScott Ganis, Partner/COO, Thayer Brook Partners LLP
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Pool Quarterly Reports and Form PR
Form and Process CFTC Form
Process for making changes
How Help Text is developed
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Pool Quarterly Reports and Form PR
NFA’s review and use of PQRs and PRs Compliance Department Structure Risk Analysis Relationship Data ROR vs. Net Income Conversations between CPO and NFA Staff
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Managing a firm’s regulatory filings
Role of Compliance and other groups/areas
Process
Documenting Assumptions
Reconciliations
Responding to NFA Staff inquiries
CPO’s Approach to Filings
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Effective for June 30th PQR Filings Additional help text in Step 2a and 2b
Recent Changes to Forms
Only include pools for which the CPO is required to be registered
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Effective for June 30th PQR Filings New question: Box 30
Recent Changes to Forms
Include all commodity pools, even those exempt under 4.13 or excluded under 4.5
Recent Changes to Forms
•New Questions Boxes 25-28 breakdown the total in Box 30
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Effective for June 30th PQR Filings Expanded help text in Step 5
Recent Changes to Forms
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Effective for June 30th Form PR Filings Additional help text in Step 1d
Recent Changes to Forms
Include only trading programs for which the CTA is required to be registered
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Effective for June 30th Form PR Filings Additional help text in Step 2a and 2b
Recent Changes to Forms
Exclude any assets that are attributable to pools for which the CPO is not required to be registeredExclude any assets that are attributable to pools that you operate as a CPO
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Effective for June 30th PR Filings Additional help text in Step 3
Recent Changes to Forms
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Effective for June 30th PR Filings New question Step 8 (Box 30)
Recent Changes to Forms
Include all managed accounts, even those for commodity pools that are exempt or excluded pursuant to 4.13 or 4.5
Boxes 25-28 breakdown the total in Box 30
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Effective for September 30th PQR Filings Added boxes 8501 and 8502 to Fixed Income section of the
Schedule of Investments
Recent Changes to Forms
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Effective for September 30th PQR Filings Additional help text was added to Step 10, Statement of AUM
regarding the use of base currencies and conversion factors
Recent Changes to Forms
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Effective for September 30th PQR Filings Additional relationship information for certain steps will persist
from quarter to quarter
Recent Changes to Forms
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Relationship start and end dates
Relationships across firms and/or forms
Pools appear on a PQR that should not be filing
Discrepancies between current and prior filings. For example, NAV or investments
Responding to NFA Staff inquiries
Common Filing Inquiries
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Update the Annual Questionnaire to delete or cease a pool, and provide specifics
Liquidation Statements
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“Ceased Trading” date
Liquidation Statements
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Impact on PQRs Disclosure to Pool Participants Audited by CPA unless waivers are obtained Required components of a liquidation statement Circumstances that do not represent a “liquidated pool”
Switching from 4.7 to 4.13 exempt pool Ceased trading commodity interests Temporary cessation of trading
Other regulatory requirements other than CFTC
Liquidation Statements
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CPO Delegation
Third-party Recordkeeping Rules
Fund-of-Fund Guidance
Consolidation of Statements
Exemption/exclusion annual affirmation process
Possible CPO and CTA Customer Protection Measures
CPO and CTA Hot Topics
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NFA’s website, www.nfa.futures.org Form PQR and Form PR templates updated quarterly 2014 Tutorial, ‘Common PQR Filing Deficiencies’ 2013 Webinar, ‘Quarterly Reporting Requirements for CTAs’
Technical Support [email protected] [email protected]
NFA’s Information Center (800) 621-3570, or (312) 781-1410
Resources
Thank you