Transcript Slide 1 - National Futures Association

CPO and CTA Filing Requirements
Tracey Hunt, Associate Director, Compliance
Mary McHenry, Associate Director, Compliance
Lauren Conway, Citadel Investment Group
Steve Farmer, Mesirow Financial
Pool Quarterly Reports and Form PR
Form and Process
• CFTC Form
• How Help Text is developed
NFA’s review and use of PQRs and PRs
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Compliance Department Structure
Risk Analysis
Relationship Data
ROR vs. Net Income
Conversations between CPO and NFA Staff
CPO’s Approach to Filings
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Managing a firm’s regulatory filings
Role of Compliance and other groups/areas
Process
Documenting Assumptions
Reconciliations
Responding to NFA Staff inquiries
Changes to the Forms
Effective for June 30th Filings
• New questions to obtain information on a firm’s
investments in futures and swaps in terms of an
approximate percentage of Total Net AUM
• Additional help text, for example
• Report assets for pools for which the CPO is required
to be registered (non-exempt pools)
• Report actual pool assets (NAV); not notional
• Expanded definition of Carrying Broker
Upcoming changes for the September 30th Filings
Common Filing Deficiencies
• Relationship start and end dates
• Pools appear on a PQR that should not be filing
• Discrepancies between current and prior filings.
For example, NAV or investments
Liquidation Statements
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When and where to update NFA’s systems
Impact on PQRs
“Ceased Trading” date
Disclosure to Pool Participants
Audited by CPA unless waivers are obtained
Required components of a liquidation statement
Circumstances that do not represent a “liquidated pool”
• Switching from 4.7 to 4.13 exempt pool
• Ceased trading commodity interests
• Temporary cessation of trading
• Other regulatory requirements other than CFTC
Resources
• NFA’s website, www.nfa.futures.org
 Form PQR and Form PR templates updated quarterly
 2014 Tutorial, ‘Common PQR Filing Deficiencies’
• NFA’s Information Center
(800) 621-3570, or
(312) 781-1410
CPO and CTA Hot Topics
• CPO Delegation
• Third-party Recordkeeping Rules
• Fund-of-Fund Guidance
• Consolidation of Statements
• Recent CFTC Letters
• Exemption/exclusion annual affirmation process