On April 24, the National Futures Association (NFA) issued a notice to members regarding amendments to NFA Compliance Rule 2-46. The amended rule modifies the NFA’s quarterly pool reporting requirements and extends related reporting deadlines to align the NFA reporting requirements with the Commodity Futures Trading Commission Form CPO-PQR reporting requirements under CFTC Regulation 4.27. Under the revised rule, large commodity pool operators (CPOs) (i.e., with assets under management (AUM) of more than $1.5 billion) will fulfill their NFA and CFTC filing obligations by submitting CFTC Form CPO-PQR within 60 days of the end of each quarter. Small CPOs (AUM of less than $150 million) and mid-size CPOs (AUM of $150 million to $1.5 billion) will satisfy their NFA filing obligations by submitting CFTC Form CPO-PQR within 90 days of the end of each calendar year and submitting NFA Form PQR (which is based substantially on Schedule A and Schedule B, Item 6, of CFTC Form CPO-PQR) within 60 days of the end of each quarter ending in March, June and September. CPOs that are dually registered as investment advisers with the Securities and Exchange Commission and file Form PF instead of CFTC Form CPO-PQR will satisfy their NFA filing obligations by submitting NFA Form PQR within 60 days of the end of each quarter ending in March, June and September and CFTC Form CPO-PQR and a Schedule of Investments within 60 or 90 days of each year end.

Under revised Compliance Rule 2-46, NFA member commodity trading advisors (CTAs) with a reporting requirement under CFTC Regulation 4.27 are required to file NFA Form PR within 45 days of the end of each calendar quarter. The NFA has not finalized a date for the first CTA filing, but noted that CTAs will not need to file quarterly reports for the quarters ended March 31 and June 30 of this year.