CFTC Staff Publishes Responses to Frequently Asked Questions Regarding Commission Forms CPO-PQR and CTA-PR

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On November 5, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission published responses (Responses) to frequently asked questions regarding Forms CPO-PQR and CTA-PR (Forms). The Responses address many questions, including: (1) who is required to complete and file the Forms; (2) how should total assets under management be calculated for purposes of determining classification as a mid-sized or large commodity pool opporator (CPO); (3) where each series of a multi-series pool has its own set of financial statements, is it acceptable for the CPO to report each series as a separate pool on the Form CPO-PQR; (4) how is “weighted average tenor” defined for the Form CPO-PQR; (5) what happens if a commodity trading advisor submits its Form CTA-PR after the due date; (6) does a sub-advisor to an advisor, both of which are registered CTAs, need to report separately on Form CTA-PR; and (7) how should a CTA report Master-Feeder Arrangements on Form CTA-PR.

The Responses are available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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