NFA Notice to Members I-20-44-Changes to the NFA Form PQR

The NFA recently issued a reminder that NFA Member CPOs are required to submit their December 31, 2020 NFA Form PQR to NFA via EasyFile (Quarterly Reports) by March 31, 2021.

NFA Compliance Rule 2-46 requires, with limited exceptions, commodity pool operator (CPO) Members to file NFA Form PQR on a quarterly basis with NFA for each pool that it operates. CFTC Regulation 4.27 imposes similar CPO reporting requirements by requiring CPOs file CFTC Form CPO-PQR. The CFTC recently amended Regulation 4.27 and the NFA similarly modified its Form PQR, which will be effective for the December 31, 2020 filing. The NFA’s new PQR template will be available on the NFA’s website on December 21, 2020.

This is an important nuance to remember because although the CFTC is not requiring a December 31, 2020 CPO-PQR filing, NFA Member CPOs are still required, pursuant to NFA Compliance Rule 2-46, to submit the December 31, 2020 NFA Form PQR to NFA via EasyFile (Quarterly Reports) by March 31, 2021.