In response to the COVID-19 pandemic, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief to commodity pool operators (CPOs) extending the upcoming filing deadlines for required pool quarterly reports on CFTC Form CPO-PQR, as well as annual reports and periodic account statements provided to pool participants. National Futures Association (NFA) also issued similar relief to CPOs for pool quarterly reporting requirements on NFA Form PQR and to commodity trading advisors (CTAs) for quarterly filings on NFA Form PR.

Relief for CPOs

Under the relief from the DSIO, the deadline for Small (AUM

DSIO also extended the filing deadline for pool annual reports that would otherwise be required to be filed with NFA and distributed to pool participants on or before April 30, 2020, on the condition that the annual certified financial statements for the affected commodity pools are filed with NFA and distributed to pool participants no later than 45 days after the original due date for such report.

Finally, DSIO extended the deadline for distributing periodic account statements to pool participants, typically required to be distributed on either a monthly or quarterly basis under CFTC rules, for all reporting periods ending on or before April 30, 2020, on the condition that such statements are distributed to participants within 45 days of the end of the applicable reporting period(s).

CPOs that comply with the terms of the DSIO’s relief providing extended due dates for any of these reports for reporting periods ending on or before April 30, 2020 will be deemed to comply with NFA’s analogous requirements.

Relief for CTAs

NFA also granted an extension for NFA Form PR, which would ordinarily be due from registered CTAs on May 15 for the quarter ending March 31, 2020, until June 30, 2020.

Both the DSIO and NFA relief is self-effectuating and does not require a separate filing or request from firms that elect to rely upon the relief.

More information about the DSIO’s no-action relief for CPOs is available here. More information regarding relief from NFA rules for CPOs and CTAs is available here.