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.