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Relief from CTA-PR filing requirement for CTAs that solely direct trading of pools for which the firm operates as a registered or exempt CPO - 10 March 2020

NFA Notice to Members I-20-09
March 2, 2020

Relief from CTA-PR filing requirement for CTAs that solely direct trading of pools for which the firm operates as a registered or exempt CPO

The CFTC recently amended CFTC Regulation 4.27 to no longer require commodity trading advisors (CTA) that solely direct trading of pools for which the firm operates as a registered or exempt commodity pool operator (CPO) to file the Form PR. This relief is effective immediately and applies to the March 31, 2020 Form PR. This relief is self-executing and CTAs are not required to file a notice of exemption to obtain it.

In order to ensure that NFA's records are accurate for determining Form PR filing requirements, any CTA that intends to take advantage of this relief must notify NFA by March 31, 2020. To do so, an authorized user must log into the CTA Annual Questionnaire, respond "No" to the question "Does the firm currently direct any trading of commodity interest accounts?", and click "Submit Filing".

Responding "No" will discontinue all future notifications to complete a Form PR. CTAs qualifying for this relief that do not notify NFA by March 31, 2020, will receive notifications to file the March 31, 2020 Form PR.

CTAs that subsequently begin directing trading of commodity interest accounts (excluding any pools that the CTA operates as a registered or exempt CPO) must immediately notify NFA of this change by responding "Yes" to the question "Does the firm currently direct any trading of commodity interest accounts?" in the CTA Annual Questionnaire. Failure to do so will result in the firm not receiving important notifications regarding its filing requirements.

If you have questions regarding this Notice, please contact Kristen Harkins, Manager, Compliance (212-513-6016 or kharkins@nfa.futures.org) or Mary McHenry, Associate Director, Compliance (312-781-1420 or mmchenry@nfa.futures.org).