UNITED STATES: CFTC Proposes Amendments to Compliance Requirements for Commodity Pool Operators on Form CPO-PQR

On 14^th April 2020, the Commodity Futures Trading Commission (CFTC) announced that it has approved a proposal to amend certain compliance requirements for commodity pool operators (CPO) in Regulation 4.27 and Form CPO-PQR.

The proposal eliminates certain pool-specific reporting requirements and questions regarding a pool’s auditors and marketers; and amends the information in existing Schedule A of the form to request Legal Entity Identifiers (LEIs) for CPOs and their commodity pools.

Proposed Regulations

• Elimination of Pool-Specific Reporting Requirements in Schedules B and C
• Elimination of the majority of the data fields set forth in Schedules B and C of current Form CPO-PQR
• Revised Form CPO-PQR would generally align with NFA Form PQR.

These amendments, if adopted, will focus Form CPO-PQR on data elements that facilitate the Commission’s oversight of CPOs and their pools while reducing overall data collection requirements for CPOs in favor of relying on data from other existing sources.