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BILLING CODE 6351-01

COMMODITY FUTURES TRADING COMMISSION

17 CFR Part 4

RIN Number 3038-XXXX

Amendments to Compliance Requirements for Commodity Pool Operators on Form 

CPO-PQR

AGENCY: Commodity Futures Trading Commission

ACTION: Notice of proposed rulemaking

SUMMARY: The Commodity Futures Trading Commission (CFTC or Commission) is 

proposing amendments to Regulation 4.27 and Form CPO-PQR, as codified at appendix 

A to part 4 of the Commission’s regulations. Specifically, the proposal would: (1) 

eliminate the pool-specific reporting requirements in existing Schedules B and C of Form 

CPO-PQR, other than the pool schedule of investments, and (2) amend the information in 

existing Schedule A of the form to request Legal Entity Identifiers (LEIs) for commodity 

pool operators (CPOs) and their operated pools that have them, and to eliminate questions 

regarding pool auditors and marketers. All CPOs would be required to file the resulting 

amended Form CPO-PQR quarterly, but would also be allowed to file NFA Form PQR, a 

comparable form required by the National Futures Association (NFA), in lieu of filing the 

revised Form CPO-PQR. Relatedly, the Commission would also no longer accept Form 

PF filing in lieu of the revised Form CPO-PQR. The Commission preliminarily believes 

that these amendments would focus Form CPO-PQR on data elements that facilitate the 

Commission’s oversight of CPOs and their pools in connection with its use of other 
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Commission data streams and regulatory initiatives while reducing overall data collection 

requirements for market participants.

DATES: Comments must be received on or before [INSERT DATE 60 DAYS AFTER 

PUBLICATION ON CFTC.GOV].

ADDRESSES: You may submit comments, identified by RIN number _____, by any of 

the following methods:

• CFTC Comments Portal: https://comments.cftc.gov. Select the “Submit 

Comments” link for this rulemaking and follow the instructions on the Public Comment 

Form.

• Mail: Christopher Kirkpatrick, Secretary of the Commission, Commodity 

Futures Trading Commission, Three Lafayette Centre, 1155 21st Street, N.W., 

Washington, DC 20581.

• Hand Delivery/Courier: Follow the same instructions as for Mail, above.

Please submit your comments using only one of these methods. Submissions 

through the CFTC Comments Portal are encouraged.

All comments must be submitted in English, or if not, accompanied by an English 

translation. Comments will be posted as received to https://comments.cftc.gov. You 

should submit only information that you wish to make available publicly. If you wish the 

Commission to consider information that you believe is exempt from disclosure under the 

Freedom of Information Act (FOIA), a petition for confidential treatment of the exempt 
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information may be submitted according to the procedures established in Commission 

Regulation 145.9.1

The Commission reserves the right, but shall have no obligation, to review, prescreen, filter, redact, refuse or remove any or all of your submission from 

https://comments.cftc.gov that it may deem to be inappropriate for publication, such as 

obscene language. All submissions that have been redacted or removed that contain 

comments on the merits of the rulemaking will be retained in the public comment file and 

will be considered as required under the Administrative Procedure Act and other 

applicable laws, and may be accessible under the FOIA.

FOR FURTHER INFORMATION CONTACT: Joshua B. Sterling, Director, at 202-

418-6700 or jsterling@cftc.gov; Amanda Lesher Olear, Deputy Director, at 202-418-

5283 or aolear@cftc.gov; Division of Swap Dealer and Intermediary Oversight, 

Commodity Futures Trading Commission, Three Lafayette Centre, 1151 21st Street, 

N.W., Washington, DC 20581.

SUPPLEMENTARY INFORMATION:

I. Introduction

Section 1a(11) of the Commodity Exchange Act (CEA or the Act)2 defines the 

term “commodity pool operator” (CPO), as any person3 engaged in a business that is of 

the nature of a commodity pool, investment trust, syndicate, or similar form of enterprise, 

and who, with respect to that commodity pool, solicits, accepts, or receives from others, 

 1 17 CFR 145.9. The Commission’s regulations are found at 17 CFR Ch. I (2019).

2 7 U.S.C. 1, et seq. (2019). The Act is accessible through the Commission’s website, https://www.cftc.gov.

3 See 17 CFR 1.3 (defining “person” to include individuals, associations, partnerships, corporations, and 

trusts). 
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funds, securities, or property, either directly or through capital contributions, the sale of 

stock or other forms of securities, or otherwise, for the purpose of trading in commodity 

interests.4 CEA section 4m generally requires each person who satisfies the CPO 

definition to register as such with the Commission.5 CEA section 4n requires registered 

CPOs to maintain books and records and file such reports in such form and manner as 

may be prescribed by the Commission.6

In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act 

(Dodd-Frank Act)7 amended the Investment Advisers Act of 1940 (Advisers Act)8 to 

require advisers to large private funds9 to register with the Securities and Exchange 

Commission.(SEC).10 Congress further directed the SEC to adopt rules requiring 

registered private fund advisers11 to file reports containing such information as is deemed 

necessary and appropriate in the public interest and for investor protection and for the 

 4 7 U.S.C. 1a(11).

5 7 U.S.C. 6m(1).

6 7 U.S.C. 6n(3)(A). Registered CPOs have regulatory reporting obligations with respect to their operated 

pools. See 17 CFR. 4.22.

7 Pub. L. 111-203, 124 Stat. 1376 (2010).

8 15 USC 80b-1 et seq.

9 Section 202(a)(29) of the Advisers Act defines the term “private fund” as “an issuer that would be an 

investment company, as defined in section 3 of the Investment Company Act of 1940 (15 U.S.C. 80a-3), 

but for section 3(c)(1) or 3(c)(7) of that Act.” See 15 U.S.C. 80ab-2(a)(29).

10 See Dodd-Frank Act section 403 of the (amending Advisers Act 203(b), 15 U.S.C. 80b–3(b), to 

incorporate private fund adviser registration); Dodd-Frank Act sections 402, 407, 408 (establishing certain 

exemptions from private fund adviser registration); Advisers Act section 202(a)(29), 15 U.S.C. 80a-3

(defining “private fund”).

11 As used in this release, the term “private fund adviser” refers to any investment adviser that is (i) 

registered or required to be registered with the SEC (including any investment adviser that is also registered 

or required to be registered with the CFTC as a CPO or CTA) and (ii) advises one or more private funds 

(including any commodity pools that satisfy the definition of “private fund”).
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assessment of systemic risk.12 Pursuant to section 204 of the Advisers Act, as amended, 

those records and reports must include, among other things, a description of the amount 

of assets under management, use of leverage, counterparty credit risk exposure, and 

trading and investment positions for each private fund advised by the adviser.13 These 

records and reports must also be made available to the Financial Stability Oversight 

Counsel (FSOC).14 Through these requirements, Congress sought to make available to 

the SEC and FSOC information regarding the size, strategies and positions of large 

private funds, which Congress believed could be crucial to regulatory attempts to deal 

with a future crisis.15

Pursuant to Advisers Act section 211, as amended, rules establishing the form and 

content of reports filed by private fund advisers that are dually registered with the SEC 

and the CFTC (together, the Commissions) must be promulgated jointly by both agencies 

after consultation with FSOC.16 Accordingly, in 2011 the Commissions jointly adopted 

sections 1 and 2 of Form PF.17 In adopting Form PF, the Commissions stated that the 

form was designed to provide FSOC empirical data from which it may make a 

determination about the extent to which the activities of private funds or their advisers 

 12 See Dodd-Frank Act section 404; Advisers Act section 204, 15 U.S.C. 80b–4(b)(5). See also 15 U.S.C. 

80b-4(b)(1) (authorizing the SEC to require each investment adviser to a private fund to file reports 

containing such information as the SEC deems necessary and appropriate in the public interest or for the 

protection of investors or for the assessment of systemic risk by the Financial Stability Oversight Council).

13 15 U.S.C. 80b–4(b)(3).

14 15 U.S.C. 80b–4(b)(7).

15 Commodity Pool Operators and Commodity Trading Advisors: Amendments to Compliance Obligations, 

76 FR 7976, 7977 (Form CPO-PQR Proposal) (Feb. 11, 2011) (citing S. Conf. Rep. No. 111-176, at 38 

(2010)).

16 15 U.S.C. 80b–11(e).

17 See Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and 

Commodity Trading Advisors on Form PF, 76 FR 71128 (Nov. 16, 2011) (Form PF Final Rule). Sections 

3 and 4 of Form PF were adopted solely by the SEC. Id.
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pose systemic risk.18 The SEC added that the policy judgements implicit in the Form PF 

reporting requirements reflected FSOC’s role as the primary user of the reported 

information and that the SEC would not necessarily have required the same scope of 

reporting if the information reported on Form PF were intended solely for the SEC’s 

use.19

Following the adoption of Form PF, and on its own initiative, the Commission

adopted its own new reporting requirement for CPOs: Form CPO-PQR and Regulation 

4.27, which requires certain CPOs to report on Form CPO-PQR.20 The Commission 

proposed this new reporting requirement after reevaluating its regulatory approach to 

CPOs in light of the 2008 financial crisis and purposes and goals of the Dodd-Frank Act

so as to determine the necessary level of regulation in the then-current economic 

environment. The amendments to Part 4, including this new reporting requirement, were

intended to: (1) align the Commission’s regulatory structure for CPOs with the purposes 

of the Dodd-Frank Act; (2) encourage more congruent and consistent regulation of 

similarly situated entities among Federal financial regulatory agencies, such as dually 

registered CPOs required to file Form PF; (3) improve accountability and increase 

transparency of the activities of CPOs and the commodity pools that they operate or 

 18 Id. at 71129.

19 Id. at 71129-30.

20 See Commodity Pool Operators and Commodity Trading Advisors: Compliance Obligations, 77 FR 

11252 (Feb. 24, 2012) (Form CPO-PQR Final Rule); 17 CFR pt. 4 app. A; 17 CFR 4.27.
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advise; and (4) facilitate a data collection that would potentially assist FSOC.21 To that 

end, the requirements of Form CPO-PQR were modeled closely after those of Form PF.22

In adopting Form CPO-PQR, the Commission indicated that the collected data 

would be used for several broad purposes, including: increasing the Commission’s 

understanding of its registrant population; assessing the market risk associated with 

pooled investment vehicles under its jurisdiction; and monitoring for systemic risk.23

Specifically, the Commission was interested in receiving information regarding the 

operations of CPOs and their pools, including their participation in commodity interest 

markets, their relationships with intermediaries, and their interconnectedness with the 

financial system at large.

24 In proposing the majority of more pool-specific questions in 

the form in particular, the Commission believed the incoming data would assist the 

Commission in monitoring commodity pools in such a way as to allow the Commission 

to identify trends over time, including a pool’s exposure to asset classes, the composition 

and liquidity of a commodity pool’s portfolio, and a pool’s susceptibility to failure in 

times of stress.25 Although the Commission recognized that the data had some 

limitations, it believed that, in light of the recent financial crisis and the sources of risk 

delineated in the Dodd-Frank Act with respect to private funds, the detailed, pool-specific 

 21 Form CPO-PQR Proposal, 76 FR at 7978.

22 Id. at 7978 (“The Commission proposes [Form CPO-PQR] to solicit information that is generally 

identical to that sought through Form PF ...”). Regulation 4.27 further provides for the filing of Form PF 

in lieu of Commission filing requirements (i.e., Form CPO-PQR) for CPOs that are dually registered with 

the SEC. See 17 CFR 4.27(d).

23 See Form CPO-PQR Final Rule, 77 FR 11252.

24 Form CPO-PQR Final Rule, 77 FR at 11266.

25 Form CPO-PQR Proposal, 76 FR at 7981.
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information to be provided in Form CPO-PQR was necessary and appropriately balanced 

to assess the risks posed by a pool or a CPO as a whole.26

After seven years of experience with Form CPO-PQR, the Commission is

reassessing the scope of Form CPO-PQR and how it aligns with the Commission’s 

current regulatory priorities. The Commission’s ability to make full use of the more 

detailed information collected under Form CPO-PQR has not met the Commission’s 

initial expectations. At the same time, however, the Commission has devoted substantial 

resources to developing other data streams and regulatory initiatives designed to enhance 

its ability to broadly surveil financial markets for risk posed by all manner of market 

participants, including CPOs and their operated pools.

Under these circumstances, and as further explained in discussion that follows, 

the Commission preliminarily believes that Form CPO-PQR could be revised in a way 

that would support the Commission’s ability to exercise its oversight of CPOs and their 

operated pools while reducing reporting burdens for market participants, thereby further

promoting the integrity, resilience, and vibrancy of the U.S. derivatives markets.

II. Overview of Current Form CPO-PQR

The amount of information that a CPO is currently required to disclose on Form 

CPO-PQR varies depending on the size of the operator and the size of the operated 

pools.27 The form identifies three classes of filers: Large CPOs, Mid-Sized CPOs, and 

Small CPOs. The thresholds for determining Large and Mid-Sized CPOs generally align 

 26 Id.

27 See 17 CFR pt. 4 app. A.
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with those in Form PF:28 a Large CPO is a CPO that had at least $1.5 billion in 

aggregated pool assets under management (AUM)29 as of the close of business on any 

day during the reporting period; a Mid-Sized CPO is a CPO that had at least $150 

million, but less than $1.5 billion, in aggregated pool AUM as of the close of business on 

any day during the reporting period. Although not defined in Form CPO-PQR, Small 

CPO, as used herein, refers to all other CPOs, i.e., a CPO that had less than $150 million 

in aggregated pool AUM during the entire reporting period. The reporting period for 

Large CPOs is any of the individual calendar quarters (ending March 31, June 30, 

September 30, and December 31); for all other CPOs, the reporting period is the calendar 

year-end.

Form CPO-PQR consists of three schedules: Schedules A, B, and C. Schedule A

requires all CPOs to disclose basic identifying information about the CPO (Part 1) and

about each of the CPO’s pools and the service providers they used (Part 2). Large CPOs 

submit Schedule A on a quarterly basis; all other CPOs submit it annually. Schedule B 

requires additional detailed information for each pool operated by Mid-Sized and Large 

CPOs regarding each pool’s investment strategy; borrowings and types of creditors; 

counterparty credit exposure; trading and clearing mechanisms; value of aggregated 

derivative positions; and a schedule of investments. Large CPOs submit Schedule B on a 

quarterly basis, while Mid-Sized CPOs submit it annually.

 28 See Instructions to Form PF, available at http://www.sec.gov/about/forms/formpf.pdf. Private fund 

investment advisers with “regulatory AUM,” as that term is defined in Form PF, of at least $150 million are 

required to file Section 1 of Form PF; private fund investment advisers with regulatory AUM equal to or 

exceeding $1.5 billion are required to file Sections 1 and 2 of Form PF. Id.

29 AUM refers to the amount of all assets that are under the control of the CPO. See 17 CFR pt. 4 app. A.
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Schedule C requires further detailed information about the pools operated by 

Large CPOs on an aggregate and pool-by-pool basis. Part 1 of Schedule C requires

aggregate information for all pools operated by a Large CPO, including (1) a 

geographical breakdown of the pools’ investment on an aggregated basis and (2) the 

turnover rate of aggregate portfolio of pools. Part 2 of Schedule C requires certain 

detailed information for each Large Pool the Large CPO operates, where a “Large Pool”

is defined as a commodity pool that has a net asset value (NAV)30 individually, or in 

combination with any parallel pool structure,31 of at least $500 million as of the close of 

business on any day during the reporting period.32 Specifically, Part 2 requires 

information with respect to each Large Pool the Large CPO operates during the given 

reporting period, including information regarding the Large Pool’s: (1) identity; (2) 

liquidity; (3) counterparty credit exposure; (4) risk metrics; (5) borrowing; (6) derivative 

positions and posted collateral; (7) financing liquidity; (8) participant information; and 

(9) the duration of its fixed income assets. Large CPOs submit Schedule C on a quarterly 

basis and Part 2 of Schedule C on a quarterly basis for each Large Pool they operate 

during the reporting period.

If a CPO is dually registered with the SEC as an Investment Adviser and is 

required to file Form PF regarding its advisory services to private funds

33 during the 

 30 The term “net asset value” has the same meaning as in Commission regulation 4.10(b). See id.

31 The term “parallel pool structure” means any structure in which one or more pools pursues substantially 

the same investment objective and strategy and invests side by side in substantially the same assets as 

another pool. See id.

32 Id.

33 The term “private fund” has the same meaning as the definition of “private fund” in Form PF. 17 CFR 

pt. 4, app. A.
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reporting period, the CPO is deemed to have satisfied its Schedule B and Schedule C

filing requirements by completing and filing certain questions in Form PF.

34

In addition to Form PF and Form CPO-PQR, in 2010 NFA implemented its form 

PQR (NFA Form PQR) to elicit data in support of a risk-based examination program for 

CPOs.35 Pursuant to NFA Rule 2-46, all CPO NFA members, which include all CPOs 

registered with the Commission, must file NFA Form PQR on a quarterly basis.36 By 

rule, NFA accepts the filing of Form CPO-PQR, but not Form PF, in lieu of filing its 

form for any quarter in which a Form CPO-PQR filing is required under Regulation 4.27. 

As such, dually-registered CPOs that file Form PF in lieu of a Form CPO-PQR filing are 

currently required to file NFA Form PQR with NFA quarterly.

III. Proposed Regulations

As indicated above, the Commission is proposing amendments to Form CPOPQR that would reduce the amount of reporting required thereunder while still supporting 

the Commission’s ability to oversee the activities of CPOs and their operated pools. 

Notably, the proposal would eliminate the pool-specific information currently required to 

be reported in Schedules B or C of the form, with the exception of the pool schedule of 

investments (question 6 of Schedule B). The information required in current Schedule A 

would remain with a few amendments, notably the addition of questions regarding LEIs. 

The retained reporting requirements – the reporting requirements in current Schedule A, 

as proposed to be amended, plus the schedule of investments from Schedule B – would 

 34 See id.

35 NFA Rule 2-46 (2010).

36 Id. All registered CPOs are required to be NFA members pursuant to 17 CFR 170.17.
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be combined to form the entirety of Form CPO-PQR, referred to herein as “Revised Form 

CPO-PQR.” The proposal would require all CPOs to file Revised Form CPO-PQR on a 

quarterly basis, but would permit CPOs to file a comparable form required by NFA, NFA 

Form PQR, in lieu of Revised Form CPO-PQR. As a corollary, the Commission would 

also revise Regulation 4.27(d) to eliminate the ability of dually regulated CPOs that are 

required to file Form PF with respect to one or more of their operated private funds to file

Form PF in lieu of filing current Form CPO-PQR, while retaining Form PF as the 

Commission’s form. The sections that follow explain these proposed changes in further 

detail.

A. Elimination of Pool-Specific Reporting Requirements in Schedules B and C

As mentioned above, the Commission is proposing to eliminate the majority of 

the information required to be reported in current Schedules B and C of Form CPO-PQR. 

The eliminated data elements include detailed, pool-specific information, provided on 

both the individual and aggregate level, such as questions about investment strategy and 

counterparty credit exposure, asset liquidity and concentration of positions, clearing 

relationships, risk metrics, financing, and investor composition.

In adopting Form CPO-PQR, the Commission was interested in receiving 

information regarding the operations of CPOs and their operated pools, including their 

participation in commodity interest markets, their relationships with intermediaries, and 

their interconnectedness with the financial system at large.

37 In proposing the majority of 

the elements in Schedules B and C in particular, the Commission believed they would 

assist the Commission in monitoring commodity pools in such a way as to allow the 

 37 Form CPO-PQR Final Rule, 77 FR at 11266.
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Commission to identify trends over time, including a pool’s exposure to asset classes, the 

composition and liquidity of a commodity pool’s portfolio, and a pool’s susceptibility to 

failure in times of stress.38

After seven years of experience with Form CPO-PQR, however, the Commission 

acknowledges that challenges with the data collected in Schedules B and C, combined 

with resource constraints in the face of broader Commission priorities, have frustrated the 

Commission’s ability to fully realize that vision. To begin, in an effort to take into 

account the different ways CPOs maintain information, the Commission allowed CPOs 

flexibility in how they calculated and presented certain of the data elements.39 For 

example, Form CPO-PQR gives Large CPOs the option of reporting either the duration, 

weighted average tenor, or 10-year equivalents of fixed income portfolio holdings, 

understanding that Large CPOs may use a wide range of metrics to measure interest rate 

sensitivity. As a result, the Commission’s ability to identify trends across CPOs or pools 

using Form CPO-PQR data has been substantially challenged.

Additionally, taking into account the volume and complexity of the data it was 

requesting, the Commission determined not to require the data to be provided in real-time 

but rather only mandated post hoc quarterly or annual filings. The Commission 

acknowledged the limitations of this filing schedule at the time but also recognized the 

time it would take to produce the requested information and concluded that Form CPOPQR struck an appropriate balance in addressing the Commission’s need for timely 

 38 Form CPO-PQR Proposal, 76 FR at 7981.

39 Form CPO-PQR Final Rule, 77 FR at 11271.
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information and providing CPOs sufficient time to prepare it.40 As the Commission has 

reviewed the data over the years, however, it has become apparent that the infrequent and 

delayed nature of such reporting has made it difficult to assess the impact of CPOs and 

their operated pools on markets as conditions and relative CPO risk profiles may have 

changed, potentially significantly, by the time Form CPO PQR is filed with the 

Commission.

Part of the Commission’s rationale for promulgating Schedules B and C was a 

need for additional information about CPOs that are non-dual registrants to “identify 

significant risk to the stability of the derivatives market and the financial market as a 

whole.”41 In making the assessment that the information then available about the 

operations of CPOs and their operated firms was insufficient, the Commission focused 

primarily on the limited data that it received under other provisions of Part 4, such as the 

annual pool financial statements under Regulation 4.22, which it believed was not well 

suited for the stated purpose of identifying risk to the either stability of the derivatives 

markets or the financial markets in general.

42 Moreover, the Commission did not at the 

time believe that it had the capability to use that information to assess the relationship 

between a large position held by a pool and the rest of the pool’s other derivatives 

positions and securities investments.43

 40 Form CPO-PQR Final Rule, 77 FR at 11267.

41 Id. at 11266.

42 Form CPO-PQR Proposed Rule, 76 FR at 7978 (Feb. 11, 2011) (“The information that the Commission 

currently receives is limited, not designed to measure systemic or market risk in any meaningful way, and 

is only submitted by registered CPOs on an annual basis.”).

43 Form CPO-PQR Final Rule, 77 FR at 11268.
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However, in the ten years since the Dodd-Frank Act was passed, the Commission 

has devoted significant resources to regulatory initiatives and data streams designed to 

enhance the Commission’s ability to broadly surveil financial markets for risk posed by 

all manner of market participants, including CPOs. These data streams include extensive 

information related to trading, reporting, and clearing of swaps. Notably, the 

Commission has developed a regime requiring the reporting of detailed swap transaction 

information to swap data repositories (SDRs), including for those transactions entered 

into by CPOs and the pools they operate.44 Specifically, swap transaction data related to 

both over-the-counter and exchange traded swaps is required to be reported to SDRs,

45

and consequently, swaps entered into by CPOs and pools, whether on an exchange or 

over-the-counter, are reported to SDRs and included in the data set that Commission staff 

can use to conduct broader market surveillance.

The Commission has also maintained, and in some instances enhanced, its daily 

reporting regime for derivatives clearing organizations (DCOs), clearing members, 

designated contract markets (DCMs), futures commission merchants (FCMs), swap 

dealers, and large traders. Commission regulations require DCOs to make extensive 

daily reports, containing information on the positions and activities of clearing members 

and customers, including commodity pools, to the Commission.46 Commission 

regulations also require reporting by clearing members and large traders themselves.47

Through this data, the Commission can analyze positions and risks at the DCO, clearing 

 44 See 17 CFR pts. 45, 49; App. 1 to pt. 45.

45 17 CFR pt. 45.

46 17 CFR 39.19.

47 17 CFR pt. 18.
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member, or customer level, including customer positions at more than one clearing 

member, and clearing member positions at more than one DCO.

The Commission’s risk surveillance program focuses on identifying, quantifying, 

and monitoring the risks to the financial system posed by DCOs, clearing participants, 

and other market participants – including CPOs and their operated pools. To this end, on 

a daily basis, Commission staff work to: (1) identify positions in cleared products that 

pose significant financial risk; and (2) confirm that these risks are being appropriately 

managed. Staff undertakes these tasks at the customer level, the firm level, and the DCO 

level. That is, staff identifies both the customers that pose risks to clearing members and 

clearing members that pose risks to DCOs.

Importantly, most of the transaction and position information the Commission 

uses for its surveillance activities is available on a more timely and frequent basis than 

the data received on the current iteration of Form CPO-PQR. Furthermore, Commission 

programs to conduct surveillance of exchanges, FCMs, and DCOs already include CPOs 

and do not rely on the information contained in Schedules B and C of Form CPO-PQR.

Taken together, these efforts have enhanced the Commission’s ability to broadly 

and actively surveil financial markets, including with respect to the activities of CPOs 

and the pools they operate. In general, the Commission’s alternate data streams provide a 

more timely, standardized, and reliable view into relevant market activity than that 

provided under Form CPO-PQR, which make them much easier to combine into a 

holistic surveillance program. Although none of the Commission’s current data streams 

offers a substitute for the more detailed, pool-specific type of information set forth in

Schedules B and C of Form CPO-PQR, the Commission preliminarily believes that, 
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taking into account the Commission’s current priorities and resource availabilities, a

Revised Form CPO-PQR that could be more easily integrated with these existing and 

more developed data streams would enable the Commission, with some additional data 

analysis, to oversee and assess the impact of CPOs and their operated pools in the 

commodity interest markets in an effective manner. The inclusion of the LEIs for the 

CPO and its operated pools, as explained more fully below, would be key to helping 

facilitate this integration with respect to CPOs and pools that engage in the swaps 

markets. The Commission also preliminarily believes that this improved data integration 

would mitigate the need to engage in a more extensive, and likely more burdensome,

effort to improve the utility of the data fields requested in current Schedules B and C.

The Commission notes that more than half of the largest CPOs and pools are 

captured within the statutory definitions of private fund investment advisers and private 

funds and as such are required to report on Form PF.48 Other large asset managers that 

are registered as CPOs and file Form CPO-PQR are sponsors or advisers to investment 

companies registered under the Investment Company Act of 1940,49 which, by definition, 

are not private funds.50 Many of those registered investment companies are also 

commodity pools that trade commodity interests to a meaningful degree as part of their 

investment strategies; as a result, those investment companies’ principal investment 

advisers have registered with the Commission as CPOs.51 Registered investment 

 48 Based on the data received for the reporting period of September 30, 2017, for example, eight out of the 

ten largest CPOs filed Form PF in lieu of Form CPO-PQR.

49 15 U.S.C. 80a-1, et seq.

50 15 U.S.C. 80b-2(29).

51 17 CFR 4.5(c); 17 CFR 4.12(c).
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companies are subject to a comprehensive scheme of periodic financial reporting under 

the federal securities laws, and most of that data is publicly available on the SEC’s 

website through its EDGAR filing system.52 In addition, all CPOs file annual certified 

financial statements for their commodity pools with NFA pursuant to the Commission’s 

regulations.53 NFA reviews the information in commodity pool annual certified financial 

statements, uses it as an input for determining the frequency and scope of its 

examinations of CPOs in combination with the data that it collects on its NFA Form 

PQR, and communicates frequently with Commission staff regarding its examination of 

CPOs, as informed by its review of such financial statements and data filings

The Commission acknowledges that a determination to no longer routinely collect 

the pool-specific data in Schedules B and C would result in this information not being 

readily available to FSOC upon request, which was part of the Commission’s envisioned 

purposes for Form CPO-PQR when it was first promulgated. As well, the Commission 

notes that many dually registered CPOs currently include commodity pools that are not 

private funds in data that they report on Form PF, in lieu of a filing on Form CPO-PQR 

for such pools, pursuant to Regulation 4.27(d), and that if the amendments proposed 

herein are adopted as final, these CPOs could decide to stop including these pools in their 

Form PF filing. The Commission understands that this could result in less information 

relevant to commodity pools being available to FSOC from Form PF. However, given 

 52 For instance, registered management investment companies – a category that includes those investment 

companies that are also commodity pools – file with the SEC annual reports on Form N-CEN, quarterly 

reports of their portfolio holdings on Form N-PORT, and information about their liquidity on Form NLIQUID. Management investment companies that are regulated as money market funds are subject to 

different reporting, as are other registered investment companies that are organized as unit investment 

trusts, business development companies, and face-amount certificate companies.

53 17 CFR 4.7(b); 4.22(c) and (d).
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that FSOC is otherwise provided with comparable data for the sizeable number of dually 

registered CPOs via Form PF, the Commission preliminarily believes FSOC’s monitoring 

should not be materially affected compared to its current state. 

B. Revised Form CPO-PQR

With the proposed elimination of the majority of the data fields set forth in 

Schedules B and C of current Form CPO-PQR, the resulting Revised Form CPO-PQR 

would consist of the information currently reported in Schedule A of Form CPO-PQR, 

with a couple deletions discussed below; the pool schedule of investments, currently 

reported under question 6 of Schedule B; and new questions to solicit LEIs for each CPO 

and its operated pools. All CPOs would be required to report all of this information 

quarterly, regardless of their AUM. As intimated above, the Commission preliminarily 

believes that this information, when integrated with other data streams available to the 

Commission, would provide an effective and efficient way for the Commission to 

oversee and assess the impact of CPOs and their operated pools in the commodity interest 

markets.

Current Schedule A provides the Commission basic identifying information about 

the CPO and its operated pools and the service providers they used, including the 

custodians and brokers used by the CPO with respect to some or all of the operated pools’ 

assets and the pools’ monthly rate of return. The Commission preliminarily believes that 

this basic, demographic information is useful in providing context with respect to the 

more granular information it receives regarding the positions held by commodity pools 

from other sources.
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At the moment, the data currently collected in Form CPO-PQR cannot be easily 

aggregated with other market information that the Commission collects, and, as such, has 

not been integrated into the Commission’s market oversight function, which limits its 

utility to the Commission. Specifically, the lack of LEI information for CPOs and their 

operated pools makes it challenging to align it with the data received from DCOs, DCMs, 

SDRs, and FCMs to compile a view into the operations of CPOs and pools and the 

various roles such entities inhabit within the commodity interest markets. The 

Commission is therefore proposing to amend Form CPO-PQR to include a question 

seeking the CPO’s and the operated pools’ LEIs, to the extent they have them. The 

inclusion of existing LEIs within this smaller data set on Revised Form CPO-PQR should 

enable the Commission to more efficiently and accurately synthesize the various 

Commission data streams on an entity-by-entity basis. Furthermore, inclusion of LEIs

may permit better use of SDR and other data to illuminate the risk inherent in pools and 

pool families. The Commission also anticipates that the inclusion of LEIs would greatly 

facilitate the aggregation of data from commodity pools under different levels of common 

control. 

Although the Commission is proposing to continue to receive the majority of the 

information currently collected in Schedule A of Form CPO-PQR, it is also proposing to 

eliminate the questions regarding the pool’s auditors and marketers. The Commission 

and NFA receive information regarding the independent certified public accountants that 

all CPOs are required to engage to prepare certified annual reports, including audited 

financial statements, for their operated commodity pools, which the Commission 

preliminarily believes obviates the need for obtaining this information through Revised 
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Form CPO-PQR.54 With respect to a pool’s marketers, staff generally accesses this 

information through sources other than Form CPO-PQR, such as registration records for 

APs associated with the offered pool’s CPO or through the disclosure document for the 

pool. For example, persons soliciting for pool participation units are typically either 

associated persons of the CPO55 or registered representatives of a broker dealer.56 Such 

persons are subject to regulation by either the Commission and NFA, or the SEC and the 

Financial Industry Regulatory Authority (FINRA). As such, the Commission 

preliminarily believes that it readily has the means to learn who such persons are with 

respect to the offering of participation units in a particular commodity pool without 

requiring that information to be reported on Form CPO-PQR. 

At present, most CPOs are only required to submit the information in Schedule A 

of Form CPO-PQR on an annual basis; only Large CPOs submit this information 

quarterly. In order to fully integrate the information reported on Revised Form CPOPQR into the Commission’s ongoing oversight of the derivatives markets and commodity 

pool industry, the Commission preliminarily believes that the reporting of this basic 

information on a more frequent quarterly basis would be necessary. The Commission 

therefore preliminarily believes that requiring reporting of this basic information on a 

more frequent quarterly basis would play an important role in facilitating Commission’s 

ability to monitor trends in the commodity pool industry. 

 54 17 CFR 1.16.

55 17 CFR 1.3, associated person; 17 CFR 3.12.

56 17 CFR 3.12(h)(ii).
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The pool schedule of investments, currently in Schedule B, provides the 

Commission a fairly detailed breakdown of how the pool’s investments are allocated by 

asset category (cash, equities, alternative investments, fixed income, derivatives, options, 

and funds). Although under the current iteration of Form CPO-PQR only Mid-Sized and 

Large CPOs are required to submit any information in Schedule B, and Mid-Sized CPOs 

only submit it annually, the Commission preliminarily believes that obtaining a pool 

schedule of investment from all CPOs with respect to their operated pools on a regular, 

quarterly basis would assist the Commission in understanding the composition of a pool’s 

portfolio with a limited, if any, increase in their filing burden as the Commission notes 

that NFA Form PQR currently requires all CPOs regardless of size to file a pool schedule 

of investments each quarter. 

C. NFA Form PQR

As proposed, Revised Form CPO-PQR would generally align with NFA Form 

PQR. NFA Form PQR was implemented in 2010 to elicit data to implement NFA’s riskbased examination program for CPOs. 57 The form requests basic identifying information 

for CPOs and their operated pools, and a schedule of investments, and requires all CPOs 

to report this information quarterly. As a whole, current NFA Form PQR is essentially 

identical to current Schedule A of Form CPO-PQR combined with the pool of 

investments question from Schedule B. The Commission also understands that NFA has 

plans to include questions regarding LEIs in NFA Form PQR. If Revised Form CPO-

 57 NFA Form PQR assists NFA in assessing risks, identifying trends, and assigning audit priorities in its 

oversight of CPOs. See National Futures Association: CPO Quarterly Reporting Requirements – Proposed 

Adoption of Compliance Rule 2-46, 

https://www.nfa.futures.org/news/PDF/CFTC/CR2_46_CPO_Quarterly_Report_082009.pdf (last visited 

Dec. 30, 2019).
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PQR is adopted as proposed, and NFA’s amendments to include LEIs are also finalized, 

the forms will be substantively identical. Under those circumstances, the Commission 

would permit a CPO to file NFA Form PQR in lieu of Revised Form CPO-PQR, offering 

CPOs additional filing efficiencies without compromising the Commission’s ability to 

obtain affected data.

As a corollary, the Commission is also proposing to revise Regulation 4.27(d), 

which currently permits dually regulated CPOs required to file Form PF with respect to 

one or more of their operated private funds to file Form PF in lieu of filing current Form 

CPO-PQR with respect to any commodity pools that are not private funds.58 The 

Commission believes that this provision would be redundant in light of the proposed 

provision to accept NFA Form PQR and would frustrate an intended purpose of this 

proposed rulemaking, which is to allow the Commission to enhance the Commission’s 

use of its own internal data streams to effectuate an efficient and effective oversight 

program of CPOs and their operated pools, given that Revised Form CPO-PQR would no 

longer be closely aligned in content or filing frequency with Form PF. The Commission 

is not, however, proposing to change Form PF’s status as the Commission’s form, nor is 

the Commission proposing to change its requirement that dually registered CPOs and 

CTAs continue to file Form PF with the SEC.

Many dually registered CPOs currently include commodity pools that are not 

private funds in data that they report on Form PF, in lieu of a filing on Form CPO-PQR 

for such pools, in reliance on Regulation 4.27(d). If Regulation 4.27(d) is revised to 

eliminate this option for dually registered CPOs, the Commission understands that some 

 58 17 CFR 4.27(d). 
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or even all dually registered CPOs that currently file Form PF in lieu of Schedules B 

and/or C of current Form CPO-PQR for their non-private fund pools could cease to 

include such non-private fund pools in their Form PF filings, resulting in a reduced data 

set collected on Form PF as compared to the status quo. The Commission preliminarily 

believes, however, that this loss of data to the SEC and FSOC would not meaningfully 

impact the efficacy and intent of Form PF in furthering the oversight of the private fund 

industry, given that it would only result in the loss of data on Form PF with respect to 

non-private fund pools.

59

IV. Request for Comments

The Commission requests comment on all aspects of this proposal. Additionally,

the Commission would appreciate consideration of the following specific questions:

A. Scope of Proposed Revised Form CPO-PQR

1. CPOs that are jointly regulated by the Commission and the SEC are required to 

file Form PF with respect to private funds; many commodity pools are private funds 

within the meaning of Form PF. One of the Commission’s initial rationales for adopting 

Form CPO-PQR was to encourage more congruent and consistent regulation of similarly 

situated entities among Federal financial regulatory agencies, particularly with respect to 

dually registered CPOs required to file Form PF. If Revised Form CPO-PQR is adopted 

as proposed, Form PF and Form CPO-PQR would become less aligned, meaning that 

dually registered CPOs would have reporting obligations that are noticeably different 

 59 Form CPO-PQR Final Rule, 77 FR at 11281 (“[T]o mitigate reporting costs to regulated entities that may 

be registered with both the Commission and with the SEC, the regulations have been modified to allow 

dually registered entities to file on [F]orm PF (plus the first schedule A of [F]orm CPO-PQR) for all of 

their commodity pools, even those that are not ‘private funds.’”). As noted previously, such CPOs relying 

upon on the Commission’s acceptance of Form PF in lieu of a Form CPO-PQR filing are currently required 

to file NFA Form PQR on a quarterly basis under NFA Rule 2-46.
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from those CPOs only subject to the Commission’s jurisdiction. Would such a relative 

lack of regulatory congruence negatively impact CPOs? Should the Commission instead

rescind Form CPO-PQR in its entirety and require all CPOs to file all or part of Form PF 

with NFA? Why or why not?

2. Many dually registered CPOs currently include commodity pools that are not 

private funds in data that they report on Form PF, in lieu of a filing on Form CPO-PQR 

for such pools, pursuant to Regulation 4.27(d). If the amendments proposed herein are 

adopted as final, these CPOs could decide to stop including these pools in their Form PF 

filing. For CPOs in this category, if Form CPO-PQR is amended as proposed, would you 

cease reporting data for these pools on Form PF? Why or why not? 

3. CPOs that operate commodity pools that are registered investment companies 

must report financial information about those pools to the SEC, while also providing 

annual pool financial statements to NFA. Is there any additional reporting of investment 

company financial information that the Commission has failed to consider in this 

proposal that addresses the concerns underlying Form CPO-PQR?

4. Are there any specific questions that the Commission has proposed to rescind 

that it should consider retaining? Why?

5. Are there ways the Commission could further clarify and refine the reporting 

instructions for completing Revised CPO-PQR in order to provide CPOs with greater 

certainty that they are completing the form correctly? For example, could the form’s 

references to other regulations or its defined terms be simplified or made clearer? Please 

suggest specific revisions.

B. NFA Form PQR
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5. The Commission proposes to permit a timely filing with NFA of NFA Form 

PQR in lieu of a filing of the revised Proposed Form CPO-PQR. Should the Commission 

consider any other ways to further align with NFA Form PQR? What would those ways 

be? Please describe in detail.

6. The schedule of investments as it currently appears in both Revised Form 

CPO-PQR and NFA Form PQR requires significant granular information regarding 

numerous asset classes. Are there any asset classes that can or should be eliminated? 

Why or why not? Should the Commission consider amending the schedule of 

investments to align with the simpler schedule that appeared in NFA Form PQR in 2010?

C. Addition of LEIs

7. In order to further the analysis of Revised Form CPO-PQR across other 

existing Commission data sets, the Commission is proposing to require the inclusion of 

LEIs in Revised Form CPO-PQR, to the extent that the CPO or its operated pools 

otherwise already have LEIs. The inclusion of LEIs would also make this portion of 

Form CPO-PQR data more accessible for analysis consistent with these other data sets. 

Should the Commission include LEIs on Revised Form CPO-PQR? Why or why not?

V. Related Matters 

A. Regulatory Flexibility Act 

The Regulatory Flexibility Act (RFA) requires Federal agencies, in promulgating 

regulations, to consider whether the rules they propose will have a significant economic 

impact on a substantial number of small entities and, if so, to provide a regulatory 

flexibility analysis regarding the economic impact on those entities. Each Federal agency 

is required to conduct an initial and final regulatory flexibility analysis for each rule of 
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general applicability for which the agency issues a general notice of proposed 

rulemaking.60 

The regulatory amendments proposed by the Commission today would affect only 

persons registered or required to be registered as CPOs. The Commission has previously 

established certain definitions of “small entities” to be used by the Commission in 

evaluating the impact of its rules on such entities in accordance with the requirements of 

the RFA.61 With respect to CPOs, the Commission previously has determined that a 

CPO is a small entity for purposes of the RFA, if it meets the criteria for an exemption 

from registration under § 4.13(a)(2).62 Because the regulations proposed today generally 

apply to persons registered or required to be registered as CPOs with the Commission, as 

well as from related compliance burdens, the RFA is not applicable to this Proposal.

Accordingly, the Chairman, on behalf of the Commission, hereby certifies 

pursuant to 5 U.S.C. 605(b) that these proposed amendments, if adopted, will not have a 

significant economic impact on a substantial number of small entities.

B. Paperwork Reduction Act

1. Overview

The Paperwork Reduction Act (PRA) imposes certain requirements on Federal 

agencies in connection with their conducting or sponsoring any collection of information 

 60 5 U.S.C. 601 et seq.

61 See, e.g., Policy Statement and Establishment of Definitions of “Small Entities” for Purposes of the 

Regulatory Flexibility Act, 47 FR 18618, 18620 (Apr. 30, 1982).

62 Id. at 18619-20. Section 4.13(a)(2) exempts a person from registration as a CPO when: 1) none of the 

pools operated by that person has more than 15 participants at any time, and 2) when excluding certain 

sources of funding, the total gross capital contributions the person receives for units of participation in all 

of the pools it operates or intends to operate do not, in the aggregate, exceed $400,000. See 17 CFR 

4.13(a)(2).
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as defined by the PRA.63 Under the PRA, an agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it displays a 

currently valid control number from the Office of Management and Budget (OMB). 

Today’s Proposal, if adopted, would result in a collection of information within the 

meaning of the PRA, as discussed below. The Commission is therefore submitting this 

NPRM to OMB for review.

The Proposal amends a single collection of information for which the 

Commission has previously received a control number from OMB. This collection of 

information is, “Rules Relating to the Operations and Activities of Commodity Pool 

Operators and Commodity Trading Advisors and to Monthly Reporting by Futures 

Commission Merchants, OMB control number 3038-0005” (Collection 3038-0005).

Collection 3038-0005 primarily accounts for the burden associated with part 4 of the 

Commission’s regulations that concern compliance obligations generally applicable to 

CPOs and CTAs, as well as certain enumerated exemptions from registration as such and 

exclusions from those definitions, and available relief from compliance with certain 

regulatory requirements. 

As discussed above, the Commission’s Proposal includes substantive changes to 

current Form CPO-PQR, such as (1) amending Schedule A, which would constitute the 

entirety of Proposed Form CPO-PQR, to add LEIs for each CPO and pool, (2) moving 

Schedule B’s “Schedule of Investments” section to Schedule A, and (3) rescinding the 

remainder of the Form’s current Schedules B and C.64 Additionally, the Commission is 

 63 See 44 U.S.C. 3501 et seq.

64 See infra pt. III.A.
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proposing to permit the filing of NFA Form PQR with NFA in lieu of filing Form CPOPQR by CPOs registered with the Commission. Therefore, the Commission is also 

proposing herein to amend Collection 3038-0005, such that the collection is consistent 

with the proposed restructuring of Form CPO-PQR, and reflects the expected adjustment 

in burden hours for registered CPOs filing the form, if revised as proposed, including the 

ability to file NFA Form PQR in lieu of filing Revised Form CPO-PQR. 

This Proposal is not expected to impose any significant new burdens on CPOs. 

Rather, because approximately half of registered CPOs are Mid-Sized or Large CPOs 

under the current filing regime and will have to answer fewer questions as compared to

the current filing requirements, and because the Commission anticipates that CPOs 

currently classified as Small CPOs will file their NFA Form PQR in lieu of the Revised 

Form CPO-PQR, it is reasonable for the Commission to infer that the proposed 

amendments will generally prove to be either less burdensome or without new net burden 

for all CPOs. The Commission is, however, amending the burden associated with the 

collection to reflect the increased frequency of filing for all CPOs to quarterly and 

increasing the hours per filing to reflect the addition of the pool schedule of investments 

to the questions in Revised Form CPO-PQR that were derived from current Schedule A. 

Although these proposed amendments result in an increase in the burden hours associated 

with Revised Form CPO-PQR, the Commission preliminarily expects that, in practice, 

CPOs will either experience no change in their burden or a decrease in burden.

As discussed above, the Commission is proposing herein to accept the filing of 

NFA Form PQR in lieu of a filing on Revised Form CPO-PQR. Because under the 

proposal any data filed on NFA Form PQR would become data collected by the 
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Commission, the burden associated with NFA Form PQR must be included in a 

collection of information with an OMB control number. Therefore, the Commission is 

amending the current burden associated with OMB Control Number 3038-0005 to also 

reflect the burden resulting from NFA Form PQR, which the Commission estimates to be 

substantively identical to that derived from Revised Form CPO-PQR.

Despite the fact that the Commission is proposing to accept the filing of NFA 

Form PQR in lieu of a filing on Revised Form CPO-PQR, the Commission preliminarily 

believes that it is necessary to retain its own form for data collection purposes to ensure 

that it retains the authority to address its data needs regarding CPOs in the future on a 

unilateral basis should the need arise. Moreover, given the Commission’s preliminary 

expectation that it would incorporate the information collected on Revised Form CPOPQR more consistently with its other data streams, the Commission preliminarily 

believes that retaining its own form independent of NFA’s form avoids any appearance of 

the Commission leveraging NFA to avoid complying with the obligations associated with 

rulemaking. The Commission also preliminarily believes that doing so will ensure that 

members of the public will be able to exercise their rights to engage in comment as to the 

content and structure of the form consistent with the Administrative Procedures Act 

going forward.65 Therefore, the Commission has preliminarily concluded that the 

amendments to Form CPO-PQR proposed herein are not unnecessarily duplicative to 

information otherwise reasonably accessible to the Commission.

2. Revisions to the Collections of Information: OMB Control Number 3038-0005

 65 5 U.S.C. §500, et. seq.
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Collection 3038-0005 is currently in force with its control number having been 

provided by OMB, and it was renewed recently on January 30, 2019.66 As stated above, 

Collection 3038-0005 governs responses made pursuant to part 4 of the Commission’s 

regulations, pertaining to the operations of CPOs and CTAs, including the required 

responses of registered CPOs on Form CPO-PQR pursuant to Regulation 4.27. 

Generally, the Commission is proposing adjustments, discussed below, to the information 

collection that result in an increase in the burden hours associated with the collection of 

information on the Revised Form CPO-PQR. The Commission preliminarily believes, 

however, as previously stated, that CPOs currently categorized as either Mid-Sized or 

Large CPOs are expected to experience a reduction in burden relative to the current filing 

requirements under Regulation 4.27 and Form CPO-PQR, and Small CPOs under the 

current filing requirements are expected to experience no increase in burden because they 

are currently required to file NFA Form PQR, which includes a schedule of investments 

that is identical to that under Revised Form CPO-PQR, on a quarterly basis, and, under 

this proposal, such CPOs would be permitted to file NFA Form PQR in lieu of filing 

Revised CPO-PQR. 

The currently approved total burden associated with Collection 3038-0005, in the 

aggregate, is as follows:

Estimated number of respondents: 45,097.

Annual responses for all respondents: 118,824.

 66 See Notice of Office of Management and Budget Action, OMB Control No. 3038-0005, available at 

https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201701-3038-005 (last retrieved July 31, 2018).
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Estimated average hours per response: 3.16.67

Annual reporting burden: 375,484.

The portion of the aggregate burden that is derived from the current Form CPOPQR filing requirements is as follows.

Schedule A (for non-Large CPOs and Large CPOs filing Form PF):

Estimated number of respondents: 1,450

Annual responses for all respondents: 1,450.

Estimated average hours per response: 6.

Annual reporting burden: 8,700.

Schedule A (for Large CPOs not filing Form PF):

Estimated number of respondents: 250.

Annual responses for all respondents: 1,000.

Estimated average hours per response: 6.

Annual reporting burden: 6,000.

Schedule B (for Mid-Sized CPOs):

Estimated number of respondents: 400.

Annual responses for all respondents: 400.

Estimated average hours per response: 4.

Annual reporting burden: 1,600.

Schedule B (for Large CPOs not filing Form PF):

Estimated number of respondents: 250.

 67 The Commission rounded the average hours per response to the second decimal place for ease of 

presentation.
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Annual responses for all respondents: 1,000.

Estimated average hours per response: 4.

Annual reporting burden: 4,000.

Schedule C (for Large CPOs not filing Form PF):

Estimated number of respondents: 250.

Annual responses for all respondents: 1,000.

Estimated average hours per response: 18.

Annual reporting burden: 18,000.

The burden associated with NFA Form PQR is as follows:

Estimated number of respondents: 1,700

Annual responses by each respondent: 6,800.

Estimated average hours per response: 8.

Annual reporting burden: 54,400.

Total annual reporting burden for all CPOs for current Form CPO-PQR and NFA 

Form PQR: 86, 900.

The Commission is proposing to no longer estimate burden hours according to 

each individual Schedule of Form CPO-PQR, because, pursuant to the Proposal, Revised 

Form CPO-PQR will only consist of one schedule. Therefore, the Commission is 

proposing to simplify the collection for Form CPO-PQR compliance to a single burden 

hours estimate for each registered CPO completing Revised Form CPO-PQR in its 

entirety.68 As noted above, the Commission is also proposing to require that Revised 

 68 The Commission is also proposing to accept NFA Form PQR in lieu of Revised Form CPO-PQR filing 

requirement, which the Commission has designed purposefully to be very similar. See supra pt. III.B. The 
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Form CPO-PQR be filed quarterly by each registered CPO, regardless of the size of their 

operations, which would result in four (4) annual responses by each respondent. Further, 

in the Commission’s experience, the schedule of investments comprised a considerable 

portion of the burden hours previously associated with completing Schedule B, 

depending on the complexity of a CPO’s operations and the number of pools it operates. 

Thus, the Commission is proposing an estimated average hours per response to ensure 

that burden continues to be counted. As noted above, although the estimated hours per 

response is expected to increase due to the retention of the schedule of investments and 

the frequency of response will increase as well for Small and Mid-Sized CPOs, as well as 

those Large CPOs filing Form PF, CPOs should not experience an increase in burden 

because all CPOs are already required to provide an identical schedule of investments as 

part of their existing NFA Form PQR filing requirement, which must be submitted on a 

quarterly basis, and the Commission preliminarily believes that CPOs will continue to 

make such filing in lieu of the Revised Form CPO-PQR.

Therefore, the Commission estimates the burden to registered CPOs for 

completing Revised Form CPO-PQR, as proposed herein, and NFA Form PQR, because 

of the option to file this form in lieu of Revised Form CPO-PQR, to be as follows:

For Revised Form CPO-PQR and NFA Form PQR for All Registered CPOs:

Estimated number of respondents: 1,700

Annual responses by each respondent: 6,800.

Estimated average hours per response: 8.

 

PRA estimates proposed herein assume that all registered CPOs will either file Revised Form CPO-PQR on 

a quarterly basis, or NFA Form PQR , but in no event will a CPO be required to file both. 
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Annual reporting burden: 54,400.

The new total burden associated with Collection 3038-0005, in the aggregate, 

reflecting the adjustment in burden associated with § 4.27 and Revised Form CPO-PQR, 

is as follows:

Estimated number of respondents: 43,062.

Annual responses for all respondents: 113,980.

Estimated average hours per response: 3.25.

Annual reporting burden: 370,467.

3. Request for Comments on Collection

The Commission invites the public and other Federal agencies to comment on any 

aspect of the proposed information collection requirements discussed above. Pursuant to 

44 U.S.C. 3506(c)(2)(B), the Commission solicits comments in order to (i) evaluate 

whether the proposed collections of information are necessary for the proper performance 

of the functions of the Commission, including whether the information will have practical 

utility; (ii) evaluate the accuracy of the Commission’s estimate of the burden of the 

proposed collections of information; (iii) determine whether there are ways to enhance 

the quality, utility, and clarity of the information proposed to be collected; and (iv) 

minimize the burden of the proposed collections of information on those who are to 

respond, including through the use of appropriate automated collection techniques or 

other forms of information technology.

Those desiring to submit comments on the proposed information collection 

requirements should submit them directly to the Office of Information and Regulatory 

Affairs, OMB, by fax at (202) 395-6566, or by email at 
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OIRAsubmissions@omb.eop.gov. Please provide the Commission with a copy of 

submitted documents, so that all comments can be summarized and addressed in the final 

rule preamble. Refer to the ADDRESSES section of this NPRM for comment 

submission instructions to the Commission. A copy of the supporting statements for the 

collections of information discussed above may be obtained by visiting 

http://www.RegInfo.gov. OMB is required to make a decision concerning the collections 

of information between 30 and 60 days after publication of this document in the Federal 

Register. Therefore, a comment is best assured of having its full effect if OMB receives 

it within 30 days of publication. 

C. Cost-benefit Considerations.

Section 15(a) of the CEA requires the Commission to consider the costs and 

benefits of its discretionary actions before promulgating a regulation under the CEA or 

issuing certain orders.69 Section 15(a) further specifies that the costs and benefits shall 

be evaluated in light of five broad areas of market and public concern: (1) Protection of 

market participants and the public; (2) efficiency, competitiveness, and financial integrity 

of swaps markets; (3) price discovery; (4) sound risk management practices; and (5) other 

public interest considerations. The Commission considers the costs and benefits resulting 

from its discretionary determinations with respect to the CEA section 15(a) 

considerations.

As discussed above, the Commission is proposing amendments to Form CPOPQR that would significantly reduce the amount of reporting required thereunder. 

Specifically, the proposal would: (1) eliminate the pool-specific reporting requirements 

 69 7 U.S.C. 19(a).
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

37

in existing Schedules B and C of Form CPO-PQR, other than the pool schedule of 

investments (question 6 of Schedule B); (2) amend the information in existing Schedule 

A of the form to request LEIs for CPOs and their operated pools and to eliminate 

questions regarding the pool’s auditors and marketers; (3) require all CPOs to submit all 

information retained in Revised Form CPO-PQR on a quarterly basis; and (4) allow 

CPOs to file NFA Form PQR in lieu of filing the Revised Form CPO-PQR, to the extent 

NFA Form PQR is amended to include LEIs. In the sections that follow, the Commission 

considers the various costs and benefits associated with each of aspect of the proposal. 

The baseline against which these costs and benefits are compared is the regulatory status 

quo, represented by Form CPO-PQR as currently codified in Appendix A to Part 4.

The consideration of costs and benefits below is based on the understanding that 

the markets function internationally, with many transactions involving U.S. firms taking 

place across international boundaries; with some Commission registrants being organized 

outside of the United States; with some leading industry members typically conducting 

operations both within and outside the United States; and with industry members 

commonly following substantially similar business practices wherever located. Where 

the Commission does not specifically refer to matters of location, the discussion of costs 

and benefits below refers to the effects of this proposal on all activity subject to the 

proposed and amended regulations, whether by virtue of the activity’s physical location 

in the United States or by virtue of the activity’s connection with or effect on U.S. 
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

38

commerce under CEA section 2(i).70 Some CPOs are located outside of the United 

States.

1. Elimination of Pool-Specific Reporting Requirements in Schedules B and C

The Commission is proposing to eliminate the pool-specific reporting 

requirements in existing Schedules B and C of Form CPO-PQR, other than the pool 

schedule of investments (question 6 of Schedule B). The Commission acknowledges that 

this change, if adopted, could result in less information available to the Commission and, 

potentially, to FSOC. The detailed and specific information requested in Schedules B 

and C of Form CPO-PQR is not available to the Commission through any other of its data 

streams and, if put to its full use, would allow for monitoring of CPOs and their operated 

pools in a way that could help identify trends and points of stress. A main reason for the 

Commission’s proposal to eliminate collection of this information stems from the 

challenges associated with the data set, including that it is only reported to the 

Commission on a quarterly basis, at its most frequent. Given the limitations associated 

with the data collected, the Commission has prioritized its limited resources to pursue 

other key regulatory initiatives. 

However, considering the alternate data streams currently available to the 

Commission, the Commission preliminarily believes that the Commission could 

nevertheless effectively exercise its oversight of CPOs and their operated pools and

potentially do so in a more efficient manner if Revised Form CPO-PQR were adopted as 

proposed. Furthermore, the Commission notes that, due in part to the identified data 

quality issues, FSOC has never received any Form CPO-PQR data; however, the 

 70 7 U.S.C. 2(i).
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

39

Commission acknowledges that FSOC may receive less data as a result of the proposal, 

as some CPOs that are filing CFTC-only pool information through Form PF may stop

doing so should this proposal be adopted as final. The Commission does not, however,

believe that FSOC’s monitoring abilities would be materially affected compared to the 

current status quo should Schedules B and C largely be eliminated.

The Commission’s proposal to eliminate these reporting requirements would also 

reduce the ongoing variable compliance costs for Mid-Sized and Large CPOs, as they 

would no longer need to devote resources to compiling and reporting this data. Nor 

would CPOs be required to monitor their AUM with the specific purpose of determining

their filing obligations as there would be a single requirement for all CPOs. It is possible 

that such cost savings may allow those CPOs to devote resources to other compliance or 

operational initiatives, or to potentially pass them on to pool participants through reduced 

fees. These cost savings would be minimized, however, for any CPO that is dually 

registered with the SEC and required to file Form PF, which requires reporting of 

information substantially similar to that required in Schedules B and C of current Form 

CPO-PQR. Additionally, the proposal would not alleviate any fixed costs affected CPOs 

may have already spent in developing systems and procedures designed to meet the 

reporting requirements in Schedules B and C, particularly if, again, such CPOs are also 

required to file Form PF.

2. Revised Form CPO-PQR

The proposal would amend the information in existing Schedule A of the form to 

request LEIs for CPOs and their operated pools. The addition of this question would 

allow the Commission to be able to integrate the data provided in Revised Form CPO-
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

40

PQR with the Commission’s other more current data streams. Leveraging these other data 

sources would enable the Commission to continue its oversight and monitoring of 

counterparty risk and liquidity risk for some of the largest pools within the Commission’s 

jurisdiction, thereby focusing on areas that are relevant for assessing market and systemic 

risk, while eliminating the burden associated with the collection of the more detailed 

information in current Schedules B and C, particularly with respect to pools that may 

meet the current Large Pool threshold in the future. The addition of this field should 

create a one-time cost for CPOs required to file Revised Form CPO-PQR, as LEIs do not 

change over time, potentially allowing fields for those questions to be prepopulated for 

subsequent filings. 

The proposal would further eliminate questions regarding the pool’s auditors and 

marketers. This amendment will result in reduced reporting costs for reporting CPOs 

while not affecting the scope of information available to the Commission, as the 

Commission already receives information regarding CPO’s accountants and has alternate 

means of obtaining information about a pool’s marketers. For example, persons soliciting 

for pool participation units are typically either associated persons of the CPO or 

registered representatives of a broker dealer. Such persons are subject to regulation by 

either the Commission and NFA, or the SEC and FINRA. 

Currently, all CPOs other than Large CPOs submit the information in Schedule A 

on an annual basis. Increasing the frequency of reporting of this information will assist 

the Commission in its efforts to integrate Revised Form CPO-PQR with the 

Commission’s other more timely data sources, so as to improve the effectiveness of its 

ability to monitor and oversee the activities of CPOs and their operated pools. Although
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

41

this would result in an increased regulatory cost for Small and Mid-Sized CPOs 

compared to the regulatory status quo, the costs as actually realized by these CPOs may 

not be as significant, as they are already reporting this information on a quarterly basis to 

NFA via NFA Form PQR.

Under current Form CPO-PQR, only Mid-Sized and Large CPOs are required to 

submit a pool schedule of investments, and Mid-Sized CPOs only submit that 

information annually. The proposal would require all CPOs to submit that information 

quarterly. The Commission believes that receiving this information from all CPOs and 

more frequently would, when combined with the proposed LEI requirements, further 

enhance its ability to integrate the information in Revised CPO-PQR with its other more 

current data streams and identify trends on a more timely basis, with the ultimate goal of 

supporting its oversight and monitoring of CPOs and their operated pools for market and 

systemic risk. As with the change in reporting frequency for the information in Schedule 

A, this change would result in an increased regulatory cost compared to the regulatory 

status quo for Small and Mid-Sized CPOs, as Small CPOs would be required to develop 

the procedures and systems necessary to take on the additional reporting obligations for 

the pool schedule of investments and both Small and Mid-Sized CPOs would now report 

that information on a quarterly basis. However, all CPOs are already required to report 

this information on a quarterly basis to NFA via NFA Form PQR, meaning the actual 

costs as realized by these CPOs may not be as significant.

The proposal would allow CPOs to file NFA Form PQR in lieu of filing the 

Revised Form CPO-PQR, to the extent NFA Form PQR is amended to include LEIs, as 

the Commission understands NFA has planned. Under NFA’s rules, all CPOs regardless 
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

42

of size are currently required to file NFA Form PQR on a quarterly basis. This provision 

would therefore operate to help CPOs maintain their current filing costs without affecting 

the scope of information available to the Commission under Revised Form CPO-PQR.

As mentioned above, the Commission acknowledges that, through the proposed 

revision of Regulation 4.27(d), the proposal could result in less data being collected on 

Form PF as compared to the current status quo. Many dually registered CPOs currently 

include commodity pools that are not private funds in data that they report on Form PF, 

in lieu of a filing on Form CPO-PQR for such pools, in reliance on Regulation 4.27(d). If 

Regulation 4.27(d) is revised, these CPOs could decide to stop including these pools in 

their Form PF filing. The Commission preliminarily believes, however, that this loss of 

data to the SEC and FSOC would not meaningfully impact the efficacy and intent of 

Form PF in furthering the oversight of the private fund industry, given that it would only 

result in the loss of data with respect to non-private fund pools; however, the 

Commission acknowledges that FSOC may lose data for a specific type of private fund 

asset class, managed futures.

3. Alternatives

In lieu of amending Form CPO-PQR as proposed, the Commission could require 

all CPOs, regardless of whether they are dually registered, to file Form PF. The 

Commission preliminarily believes that this alternative could operate to increase the 

reporting burdens for CPOs that are not dually registered with the SEC without feeding 

information directly to the Commission that could be integrated with its other data 

sources to develop its internal oversight initiatives over CPOs and their operated pools. 
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

43

Alternatively, the Commission could devote resources to rectifying the challenges 

with the data reported under current Form CPO-PQR, and amend the Form to require 

greater consistency and frequency of reporting of the data fields proposed to be 

eliminated in this proposal. However, the Commission preliminarily believes that its 

limited resources could be better directed in line with its regulatory priorities, and that its 

objectives with respect to oversight of CPOs and their operated pools could be effectively 

and potentially, more efficiently, achieved through integration with existing data streams.

The Commission preliminarily believes that the proposed changes to Form CPOPQR, relative to the alternatives, would permit the Commission to discharge its 

regulatory duties with respect to CPOs and their operated pools that might have the 

greatest impact on market and systemic risk while easing reporting obligations on a 

significant number of CPOs. The Commission requests comments and data on how 

potential alternatives would impact the potential costs and benefits to market participants 

and the public. Are there any other alternatives that may provide preferable costs or 

benefits than the costs and benefits related to the Proposal?

4. Section 15(a) Factors

a. Protection of Market Participants and the Public 

The Commission preliminarily believes that the proposal would enhance the 

ability of the Commission to protect derivatives markets, its participants, and the public

by allowing it to integrate the data provided in Revised Form CPO-PQR with other 

existing, more up-to-date, data streams in a way that would allow the Commission to 

better exercise its oversight of CPOs and their operated pools. The Commission notes 
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

44

that the amendments proposed herein could result in a loss of data available to FSOC, 

which could limit FSOC’s visibility into the activities of CPOs and their operated pools.

b. Efficiency, Competitiveness, and Financial Integrity of Markets

The Commission preliminarily believes that the proposal would assist the 

Commission in its efforts to support market efficiency, competitiveness, and financial 

integrity. Under the proposal, CPOs would continue to provide useful information about 

themselves and their pools to the Commission in a way that it could incorporate with 

other data streams to improve its oversight of CPOs, their pools, and how they operate 

within and affect the derivatives markets. Additionally, the Commission preliminarily 

believes that the specific requirement that a CPO prepare a pool schedule of investments 

on a quarterly basis for each of its operated pools could result in heightened diligence by 

the CPO with respect to the pools’ ongoing operations and encourage particularly smaller 

CPOs to adopt more formalized controls for their businesses, which the Commission 

preliminarily believes would enhance the confidence of other market participants in 

transacting with CPOs and their operated pools. 

c. Price Discovery

The Commission has not identified any impact that the Proposal would have on 

price discovery.

d. Sound Risk Management Practices

Although the Commission is proposing that it no longer require CPOs and their 

operated pools to report certain risk information, the Commission recognizes that CPOs 

will likely continue to benefit from possessing systems that collect and review risk-
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

45

related information. The Commission has not identified any other impact that the 

Proposal would have on sound risk management practices.

e. Other Public Interest Considerations

The Commission has not identified any impact on any other public interest 

considerations that the Proposal would have, but seeks public comment on any public 

interest the Commission should consider in this rulemaking.

5. Request for Comments

The Commission invites public comment on its cost-benefit considerations, 

including the Section 15(a) factors described above. Commenters are invited to submit 

with their comment letters any data or other information that they may have that 

quantifies the costs and benefits of the Proposal. In addition, the Commission invites the 

public comment on the following questions.

1. Has the Commission misidentified any costs or benefits? If so, please 

explain.

2. Please explain whether CPO compliance costs would increase or decrease 

as a result of reduced reporting requirements in this Proposal? Please provide all 

quantitative and qualitative costs, including, but not limited to personnel costs and 

technological costs.

3. Would harmonization of Form CPO-PQR with other similar forms, such 

as Form PF, provide a greater savings in compliance costs? If so, please describe all 

quantitative and qualitative savings. Please provide all quantitative and qualitative costs, 

including, but not limited to personnel costs and technological costs.

D. Antitrust laws
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

46

Section 15(b) of the CEA requires the Commission to “take into consideration the 

public interest to be protected by the antitrust laws and endeavor to take the least 

anticompetitive means of achieving the purposes of the CEA, in issuing any order or 

adopting any Commission rule or regulation (including any exemption under CEA 

section 4(c) or 4c(b)), or in requiring or approving any bylaw, rule, or regulation of a 

contract market or registered futures association established pursuant to section 17 of this 

Act.”71 

The Commission preliminarily believes that the public interest to be protected by 

the antitrust laws is generally to protect competition. The Commission requests comment 

on whether the Proposal implicates any other specific public interest to be protected by 

the antitrust laws.

The Commission has considered the Proposal to determine whether it is 

anticompetitive and has preliminarily identified no anticompetitive effects. The 

Commission requests comment on whether the Proposal is anticompetitive and, if it is, 

what the anticompetitive effects are.

Because the Commission has preliminarily determined that the Proposal is not 

anticompetitive and has no anticompetitive effects, the Commission has not identified 

any less anticompetitive means of achieving the purposes of the Act. The Commission 

requests comment on whether there are less anticompetitive means of achieving the 

relevant purposes of the Act that would otherwise be served by adopting the Proposal.

List of Subjects in 17 CFR part 4

 71 7 U.S.C. 19(b).
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

47

Advertising, Brokers, Commodity futures, Commodity pool operators, Commodity 

trading advisors, Consumer protection, Reporting and recordkeeping requirements.

For the reasons stated in the preamble, the Commodity Futures Trading 

Commission proposes to amend 17 CFR part 4 as set forth below: 

PART 4 COMMODITY POOL OPERATORS AND COMMODITY TRADING 

ADVISORS

1. The authority citation for part 4 shall continue to read as follows:

Authority: 7 U.S.C. 1a, 2, 6(c), 6b, 6c, 6l, 6m, 6n, 6o, 12a, and 23.

2. Revise § 4.27(c)(1) to read as follows:

§ 4.27 Additional reporting by commodity pool operators and commodity trading 

advisors.

* * * * *

(c) Reporting.

(1) Each reporting person shall file with the National Futures Association, a report 

with respect to the directed assets of each pool under the advisement of the commodity 

pool operator consistent with appendix A to this part or commodity trading 

advisor consistent with appendix C to this part; Provided that, a commodity pool 

operator required to file NFA Form PQR with the National Futures Association for the 

reporting period may make such filing in lieu of the report required under this section 

consistent with appendix A to this part. 

* * *

(d) Investment advisers to private funds. CPOs and CTAs that are dually registered with 

the Securities and Exchange Commission, and that are required to file Form PF under the 

rules promulgated under the Investment Advisers Act of 1940, shall file Form PF with 

the Securities and Exchange Commission. Dually registered CPOs and CTAs that file 

Form PF with the Securities and Exchange Commission will be deemed to have filed 

Form PF with the Commission for purposes of any enforcement action regarding any 

false or misleading statement of a material fact in Form PF.

* * *

3. In appendix A to part 4:
Voting Draft – As approved by the Commission on 4/14/2020

(subject to technical corrections)

48

a. Remove appendix A; and

b. Add appendix A.

Appendix A to read as follows: [FORMS CPO-PQR (app. A) attached hereto]

Issued in Washington, DC on ______ __, 2020, by the Commission.

Christopher Kirkpatrick

Secretary of the Commission
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

49

COMMODITY FUTURES TRADING COMMISSION

Instructions for Using the Form CPO-PQR

CFTC Form CPO-PQR

OMB No.: 3038-XXXX

READ THESE INSTRUCTIONS CAREFULLY BEFORE COMPLETING OR REVIEWING THE REPORTING 

FORM. 

This document is not a reporting form. Do not send this document to NFA. It is a template that you may use 

to assist in filing the electronic reporting form with the NFA at: http://www.nfa.futures.org. 

You may fill out the template online and save and/or print it when you are finished or you can download the template 

and/or print it and fill it out later.

DEFINED TERMS

Words that are underlined in this form are defined terms and have the meanings contained in the Definitions of Terms 

section.

GENERAL

Read the Instructions and Questions Carefully

Please read the instructions and the questions in this Form CPO-PQR carefully. 

In this Form CPO-PQR, “you” means the CPO. 

Call the CFTC with Questions

If there is any question about whether particular information must be provided or about the manner in which particular 

information must be provided, contact the CFTC for clarification.
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50

CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

Instructions for Using the Form CPO-PQR

REPORTING INSTRUCTIONS

1. All CPOs Are Required to Complete and File the Form CPO-PQR

All CPOs are required to complete and file a Form CPO-PQR for each Reporting Period during which they satisfy the 

definition of CPO and operate at least one Pool. Further, if a pool is operated by Co-CPOs and one of them is an 

Investment Adviser, the non-Investment Adviser CPO must file relevant section(s) even though a Form PF was filed 

for that pool by the Investment Adviser CPO.

 

2. Relationship to the National Futures Association’s Form PQR

To the extent that a CPO has timely filed the National Futures Association’s Form PQR, such filing shall be deemed

to satisfy this Form CPO-PQR.

Form CPO-PQR must be completed and filed by each CPO for every Reporting Period during which they satisfy the 

definition of CPO and operate at least one Pool. All CPOs must complete and file Form CPO-PQR within 60 days of 

the close of the most recent Reporting Period. The information provided herein should be as of the last business day 

of the reporting period. 

Part 1 of Form CPO-PQR surveys basic information about the reporting CPO. Part 2 of Form CPO-PQR asks for 

more specific information about each of the CPO’s Pools, including questions about the Pool’s key relationship and 

about the Pool’s investment positions. 

3. The CPO May Be Required to Aggregate Information Concerning Certain Types of Pools

For the parts of Form CPO-PQR that request information about individual Pools, you must report aggregate 

information for Parallel Managed Accounts and Master Feeder Arrangements as if each were an individual Pool, but 

not Parallel Pools. Assets held in Parallel Managed Accounts should be treated as assets of the Pools with which 

they are aggregated.

4. I advise a Pool that invests in other Pools or funds (e.g., a “fund of funds”). How should I treat these 

investments for purposes of Form CPO-PQR?

Investments in other Pools generally. For purposes of this Form CPO-PQR, you may disregard any Pool’s equity 

investments in other Pools. However, if you disregard these investments, you must do so consistently (e.g., do not 

include disregarded investments in the net asset value used for determining whether the fund is a “Qualifying Pool”). 

For Question 9, even if you disregard these assets, you may report the performance of the entire Pool and are not 

required to recalculate performance in order to exclude these investments. Do not disregard any liabilities, even if 

incurred in connection with these investments. 

Pools that invest substantially all of their assets in other Pools or funds. If you are the CPO for a Pool that: (i) invests 

substantially all of its assets in the equity of Pools or Private Funds for which you are not the CPO; and (ii) aside from 

such Pool or Private Fund investments, holds only cash and cash equivalents and instruments acquired for the 

purpose of hedging currency exposure, then you are only required to complete Schedule A for that Pool. For all other 

purposes, you should disregard such Pools. For example, where questions request aggregate information regarding 

the Pools you advise, do not include the assets or liabilities of any such Pool.
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

Instructions for Using the Form CPO-PQR

Notwithstanding the foregoing, you must include disregarded assets in responding to Question 8.

5. I am required to aggregate funds or accounts to determine whether I meet a reporting threshold, or I am 

electing to aggregate funds for reporting purposes. How do I “aggregate” funds or accounts for these 

purposes?

Where two or more Parallel Pool Structures or Master-Feeder Arrangements are aggregated in accordance with 

Instruction 3, you must treat the aggregated funds as if they were all one Pool. Investments that a Feeder Fund

makes in a Master Fund should be disregarded, but other investments of the feeder fund should be treated as though 

they were investments of the aggregated fund.

Where you are aggregating dependent parallel managed accounts to determine whether you meet a reporting 

threshold, assets held in the accounts should be treated as assets of the Pools with which they are aggregated.

Example 1. You advise a master-feeder arrangement with one feeder fund. The feeder fund

has invested $500 in the master fund and holds a foreign exchange derivative with 

a notional value of $100. The master fund has used the $500 received from the 

feeder fund to invest in corporate bonds. Neither fund has any other assets or 

liabilities.

For purposes of determining whether the funds comprise a qualifying Pool, this 

master-feeder arrangement should be treated as a single Pool whose only 

investments are $500 in corporate bonds and a foreign exchange derivative with a 

notional value of $100. If you elect to aggregate the master-feeder arrangement for 

reporting purposes, the treatment would be the same.

Example 2. You advise a parallel pool structure consisting of two pools, named parallel pool A 

and parallel pool B. You also advise a related dependent parallel managed 

account. The account and each fund have invested in corporate bonds of Company 

X and have no other assets or liabilities. The value of parallel pool A’s investment is 

$400, the value of parallel pool B’s investment is $300 and the value of the 

account’s investment is $200.

For purposes of determining whether either of the parallel pools is a qualifying Pool, 

the entire parallel fund structure and the related dependent parallel managed 

account should be treated as a single Pool whose only asset is $900 of corporate 

bonds issued by Company X.

If you elect to aggregate the parallel fund structure for reporting purposes, you 

would disregard the dependent parallel managed account, so the result would be a 

single Pool whose only asset is $700 of corporate bonds issued by Company X.

6. I advise a Pool that invests in entities that are not Pools, or are exempt. How should I treat these 

investments for purposes of Form CPO-PQR?

Except as provided in Instruction 4, investments in funds should be included for all purposes under this Form CPOPQR. You are not, however, required to “look through” a Pool’s investments in any other entity unless the Form 

CPO-PQR specifically requests information regarding that entity or the other entity’s primary purpose is to hold 

assets or incur leverage as part of the Pool’s investment activities.

7. The Form CPO-PQR Must Be Filed Electronically with NFA
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

Instructions for Using the Form CPO-PQR

All CPOs must file their Forms CPO-PQR electronically using NFA’s EasyFile System. NFA’s EasyFile System can 

be accessed through NFA’s website at www.nfa.futures.org. You will use the same logon and password for filing 

your Form CPO-PQR as you would for any other EasyFile filings. Questions regarding your NFA ID# or your use of 

NFA’s EasyFile system should be directed to the NFA. The NFA’s contact information is available on its website.

8. All Figures Reported in U.S. Dollars

All questions asking for amounts or investments must be reported in U.S. dollars. Any amounts converted to U.S. 

dollars must use the conversion rate in effect on the Reporting Date.

9. Use of U.S. GAAP

All financial information in this Report must be presented and computed in accordance with GAAP consistently 

applied.

10. Reporting of Legal Entity Identifiers (LEIs)

Form CPO-PQR includes questions asking CPOs for LEIs for the CPO and its operated Pools. CPOs are NOT

required to obtain LEIs for themselves or their operated Pools if such CPOs or Pools are not otherwise required to 

have them. 

11. Oath and Affirmation

This Form CPO-PQR will not be accepted unless it is complete and contains an oath or affirmation that, to the best of 

the knowledge and belief of the individual making the oath or affirmation, the information contained in the document 

is accurate and complete; provided however, that is shall be unlawful for the individual to make such oath or 

affirmation if the individual knows or should know that any of the information in this Form CPO-PQR is not accurate 

and complete.
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

Form CPO-PQR Template 

DEFINITIONS OF TERMS

Affiliated Entity: The term “Affiliated Entity” means any entity is an affiliate of another entity. An entity is an affiliate 

of another entity if the entity directly or indirectly controls, is controlled by or is under common control with the other 

entity.

Assets Under Management or AUM: The term “Assets Under Management” or “AUM” means the amount of all 

assets that are under the control of the CPO.

BP: The term “BP” means basis points.

Broker: The term “Broker” means any entity that provides clearing, prime brokerage or similar services to the Pool.

CDS: The term “CDS” means credit default swap.

CCP: The term “CCP” means a central counterparty or central clearing house, such as, but not limited to: CC&G, 

CME Clearing, The Depository Trust & Clearing Corporation (including FICC, NSCC and Euro CCP), EMCF, Eurex 

Clearing, Fedwire, ICE Clear Europe, ICE Clear U.S., ICE Trust, LCH Clearnet Limited, LCH Clearnet SA, Options 

Clearing Corporation and SIX x-clear.

Commodity Futures Trading Commission or CFTC: The term “Commodity Futures Trading Commission” or 

“CFTC” means the United States Commodity Futures Trading Commission.

Commodity Pool or Pool: The term “Commodity Pool” or “Pool” has the same meaning as “commodity pool” as 

defined in section 1a(10) of the Commodity Exchange Act.

Commodity Pool Operator or CPO: The term “commodity pool operator” or “CPO” has the same meaning as 

“commodity pool operator” defined in section 1a(11) of the Commodity Exchange Act.

Commodity Trading Advisor or CTA: The term “commodity trading advisor” or “CTA” has the same meaning as 

“commodity trading adviser” as defined in section 1a(12) of the Commodity Exchange Act.

Feeder Fund: See Master-Feeder Arrangement.

Financial Institution: The term “financial institution” means any of the following: (i) a bank or savings association, in 

each case as defined in the Federal Deposit Insurance Act; (ii) a bank holding company or financial holding company, 

in each case as defined in the Bank Holding Company Act of 1956; (iii) a savings and loan holding company, as 

defined in the Home Owners’ Loan Act; (iv) a Federal credit union, State credit union or State-chartered credit union, 

as those terms are defined in section 101 of the Federal Credit Union Act; (v) a Farm Credit System institution 

chartered and subject to the provisions of the Farm Credit Act of 1971; or (vi) an entity chartered or otherwise 

organized outside the United States that engages in banking activities.

Form CPO-PQR: The term “Form CPO-PQR” means this Form CPO-PQR.

Form PF: The term “Form PF” refers to the Form PF.
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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GAAP: The term “GAAP” means U.S. Generally Accepted Accounting Principles.

Investment Adviser: The term “Investment Adviser” has the same meaning as “investment adviser” as defined in 

Section 202(a)(11) of the Investment Advisers Act of 1940.

LEI: The term “LEI” means legal entity identifier as defined in Commission Rule 45.6.

Master Fund: See Master-Feeder Arrangement.

Master-Feeder Arrangement: The phrase “Master-Feeder Arrangement” means an arrangement in which one or 

more funds (“Feeder Funds”) invest all or substantially all of their assets in a single fund (“Master Fund”). A fund 

would also be a Feeder Fund investing in a Master Fund for the purposes of this definition if it issued multiple classes 

or series of shares or interests and each class (or series) invests substantially all of its assets in shares (or other 

interests in) a single underlying Master Fund.

National Futures Association or NFA: The term “National Futures Association” or “NFA” refers to the National 

Futures Association, a registered futures association under Section 17 of the Commodity Exchange Act.

Negative OTE: The term “Negative OTE” means negative open trade equity.

Net Asset Value or NAV: The term “Net Asset Value” or “NAV” has the same meaning as “net asset value” as 

defined in Commission Rule 4.10(b).

Non-U.S. Financial Institution: A “non-U.S. Financial Institution” means any of the following Financial Institutions: 

(i) a Financial Institution chartered outside the United States; (ii) a subsidiary of a U.S. Financial Institution that is 

separately incorporated or otherwise organized outside the United States; or (iii) a branch or agency that resides in 

the United States but has a parent that is a Financial Institution chartered outside the United States.

OTC: The term “OTC” means over-the-counter.

Parallel Managed Account: The term “Parallel Managed Account” means any managed account or other pool of 

assets that the CPO operates and that pursues substantially the same investment objective and strategy and invests 

side-by-side in substantially the same assets as the identified Pool. 
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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Parallel Pool Structure: The term “Parallel Pool Structure” means any structure in which one or more Pools pursues 

substantially the same investment objective and strategy and invests side by side in substantially the same assets as 

another Pool.

Private Fund: The term “Private Fund” has the same meaning as “private fund” as defined in Form PF.

Positive OTE: The term “Positive OTE” means positive open trade equity.

Reporting Date: The term “Reporting Date” means the last calendar day of the Reporting Period for which this Form 

CPO-PQR is required to be completed and filed. For example, the Reporting Date for the first calendar quarter of a 

year is March 31; the Reporting Date for the second calendar quarter is June 30.

Reporting Period: The term “Reporting Period” means any of the individual calendar quarters (ending March 31, 

June 30, September 30, and December 31) for all CPOs.

Trading Manager: The term “Trading Manager” means any entity or individual with sole or partial authority to invest 

Pool assets or to allocate Pool assets to other managers or investee Pools (including cash management firms). 

CTAs and other CPOs can be Trading Managers; however, a CPO should not identify itself as a Trading Manager.

Secured Borrowing: The term “Secured Borrowing” means obligations for borrowed money in respect of which the 

borrower has posted collateral or other credit support. For purposes of this definition, repos are secured borrowings.

Securities and Exchange Commission or SEC: The term “Securities and Exchange Commission” or “SEC” means 

the United States Securities and Exchange Commission.

Side Arrangements and Side Letters: The term “Side Arrangements” or the term “Side Letters” means any 

arrangement that is extended to less than 100% of the Pool’s participants.

U.S. Financial Institution: The term “U.S. Financial Institution” means any of the following Financial Institutions: (i) 

a Financial Institution chartered in the United States (whether federally-chartered or state-chartered); (ii) a subsidiary 

of a Non-U.S. Financial Institution that is separately incorporated or otherwise organized in the United States; or (iii) a 

branch or agency that resides outside the United States but has a parent that is a Financial Institution chartered in 

the United States.

Unsecured Borrowing: The term “Unsecured Borrowing” means obligations for borrowed money in respect of which 

the borrower has not posted collateral or other credit support.
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

Form CPO-PQR Template 

INSTRUCTIONS FOR COMPLETING SCHEDULE A

Every CPO is required to complete and file Schedule A of this Form CPO-PQR. This Schedule A must be completed 

for every Reporting Period during which the CPO operated at least one Pool. Part 1 of Schedule A asks for 

information about the CPO. Part 2 of Schedule A asks for information about each individual Pool that the CPO

operated during the Reporting Period. CPOs must complete and file a separate Part 2 for each Pool they operated 

any time during the Reporting Period.

Unless otherwise specified in a particular question, all information provided in this Schedule A should be accurate as 

of the Reporting Date.

PART 1 · INFORMATION ABOUT THE CPO

1. CPO INFORMATION

Provide the following general information concerning the CPO: 

a. CPO’s Name:

b. CPO’s NFA ID#:

c. CPO’s LEI ID#:

d. Person to contact concerning this Form CPO-PQR: 

e. CPO’s chief compliance officer:

f. Total number of employees of the CPO:

g. Total number of equity holders of the CPO:

h. Total number of Pools operated by the CPO:

i. Telephone number and email for person identified in c. above 

2. CPO ASSETS UNDER MANAGEMENT

Provide the following information concerning the amount of Assets Under Management by the CPO:

a. CPO’s Total Assets Under Management:

b. CPO’s Total Net Assets Under Management:
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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PART 2 · INFORMATION ABOUT THE POOLS OPERATED BY THE CPO

REMINDER: The CPO must complete and file a separate Part 2 for each Pool that the CPO operated during the 

Reporting Period.

3. POOL INFORMATION

Provide the following general information concerning the Pool:

a. CPO’s Name:

b. CPO’s NFA ID#:

c. CPO’s LEI ID#:

d. Pool’s Name:

e. Pool’s NFA ID#:

f. Pool’s LEI ID#:

4. POOL THIRD PARTY ADMINISTRATORS

Provide the following information concerning the Pool’s third party administrator(s):

a. Does the CPO use third party administrators for the Pool?

If “Yes,” provide the following information for each third party administrator:

i. Name of the administrator:

ii. NFA ID# of administrator:

iii. Address of the administrator:

iv. Telephone number of the administrator:

v. Starting date of the relationship with the administrator:

vi. Services performed by the administrator:

Preparation of Pool financial statements: 

Calculation of Pool’s performance: 

Maintenance of the Pool’s books and records: 

Other: 

5. POOL BROKERS

Provide the following information concerning the Pool’s Broker(s):

a. Does the CPO use Brokers for the Pool?

If “Yes,” provide the following information for each Broker:
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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i. Name of the Broker:

ii. NFA ID# of Broker:

iii. Address of Broker

iv. Telephone number of the Broker:

v. Starting date of the relationship with the Broker:

vi. Services performed by the Broker:

Clearing services for the Pool: 

Prime brokerage services for the Pool: 

Custodian services for some or all Pool assets:

Other:

6. POOL TRADING MANAGERS

Provide the following information concerning the Pool’s Trading Manager(s):

a. Has the CPO authorized Trading Managers to invest or allocate some or all of the Pool’s Assets Under 

Management?

If “Yes,” provide the following information for each Trading Manager:

i. Name of the Trading Manager:

ii. NFA ID# of the Trading Manager:

iii. Address of the Trading Manager:

iv. Telephone number of the Trading Manager:

v. Starting date of the relationship with the Trading Manager:

vi. What percentage of the Pool’s Assets Under Management does the Trading Manager have authority to 

invest or allocate? 

7. POOL CUSTODIANS

Provide the following information concerning the Pool’s custodian(s):

a. Does the CPO use custodians to hold some or all of the Pool’s Assets Under Management?

If “Yes,” provide the following information for each custodian:

i. Name of the custodian:

ii. NFA ID# of the custodian:

iii. Address of the custodian:

iv. Telephone number of the custodian:

v. Starting date of the relationship with the custodian:
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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vi. What percentage of the Pool’s Assets Under Management is held by the custodian? 

8. POOL’S STATEMENT OF CHANGES CONCERNING ASSETS UNDER MANAGEMENT

Provide the following information concerning the Pool’s activity during the Reporting Period. For the purposes of 

this question: 

a. The Assets Under Management and Net Asset Value at the beginning of the Reporting Period are 

considered to be the same as the assets under management and Net Asset Value at the end of the previous 

Reporting Period, in accordance with Commission Rule 4.25(a)(7)(A). 

b. The additions to the Pool include all additions whether voluntary or involuntary in accordance with 

Commission Rule 4.25(a)(7)(B).

c. The withdrawals and redemptions from the Pool include all withdrawals or redemptions whether voluntary or 

not, in accordance with Commission Rule 4.25(a)(7)(C).

d. The Pool’s Assets Under Management and Net Asset Value on the Reporting Date must be calculated by 

adding or subtracting from the Assets Under Management and Net Asset Value at the beginning of the 

Reporting Period, respectively, any additions, withdrawals, redemptions and net performance, as provided in 

Commission Rule 4.25(a)(7)(E).

i. Pool’s Assets Under Management at the beginning of the Reporting Period:

ii. Pool’s Net Asset Value at the beginning of the Reporting Period:

iii. Pool’s net income during the Reporting Period:

iv. Additions to the Pool during the Reporting Period:

v. Withdrawals and Redemptions from the Pool during the Reporting Period:

vi. Pool’s Assets Under Management on the Reporting Date:

vii. Pool’s Net Asset Value on the Reporting Date:

viii. Pool’s base currency: 
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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9. POOL’S MONTHLY RATES OF RETURN

Provide the Pool’s monthly rate of return for each month that the Pool has operated. The Pool’s monthly rate of 

return should be calculated in accordance with Commission Rule 4.25(a)(7)(F). Provide the Pool’s annual rate 

of return for the appropriate year in the row marked “Annual.”

2011 2010 2009 2008 2007 2006 2005

Jan.

Feb.

March

April

May

June

July

August

Sept.

Oct.

Nov.

Dec.

ANNUAL

10. POOL SUBSCRIPTIONS AND REDEMPTIONS

Provide the following information concerning subscriptions to and redemptions from the Pool during the 

Reporting Period.

a. Has the Pool imposed a halt or any other material limitation on redemptions during the Reporting Period?

If “Yes,” provide the following information:

i. On what date was the halt or material limitation imposed?

ii. If the halt or material limitation has been lifted, on what date was it lifted?

iii. What disclosure was provided to participants to notify them that the halt or material limitation was 

being imposed? What disclosure was provided to participants to notify them that the halt or material 

limitation was being lifted?

iv. On what date(s) was this disclosure provided?

11. POOL SCHEDULE OF INVESTMENTS

Provide the Pool’s investments in each of the subcategories listed under the following seven headings: (1) Cash; 

(2) Equities; (3) Alternative Investments; (4) Fixed Income; (5) Derivatives; (6) Options; and (7) Funds. First, 

determine how the Pool’s investments should be allocated among each of these seven categories. Once you 

have determined how the Pool’s investments should be allocated, enter the dollar value of the Pool’s total 
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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investment in each applicable category on the top, boldfaced line. For example, under the “Cash” heading, the 

Pool’s total investment should be listed on the line reading “Total Cash.” After the top, boldfaced line is 

completed, proceed to the subcategories. For each subcategory, determine whether the Pool has investments 

that equal or exceed 5% of the Pool’s Net Asset Value. If so, provide the dollar value of each such investment in 

the appropriate subcategory. If the dollar value of any investment in a subcategory equals or exceeds 5% of the 

Pool’s Net Asset Value, you must itemize the investments in that subcategory.

CASH

Total Cash

At Carrying Broker

At Bank

EQUITIES Long Short

Total Listed Equities

Stocks

a. Energy and Utilities

b. Technology

c. Media

d. Telecommunication

e. Healthcare

f. Consumer Services

g. Business Services

h. Issued by Financial Institutions

i. Consumer Goods

j. Industrial Materials

Exchange Traded Funds

American Deposit Receipts

Other

Total Unlisted Equities

Unlisted Equities Issued by Financial Institutions

ALTERNATIVE INVESTMENTS Long Short

Total Alternative Investments

Real Estate

a. Commercial
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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b. Residential

Private Equity

Venture Capital

Forex

Spot

a. Total Metals

i. Gold

b. Total Energy

i. Crude oil

ii. Natural gas

iii. Power

c. Other

Loans to Affiliates

Promissory Notes

Physicals

a. Total Metals

i. Gold

b. Agriculture

c. Total Energy

i. Crude oil

ii. Natural gas

iii. Power

Other

FIXED INCOME Long Short

Total Fixed Income

Notes, Bonds and Bills

a. Corporate

i. Investment grade

ii. Non-investment grade

b. Municipal
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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c. Government

i. U.S. Treasury securities

ii. Agency securities

iii. Foreign (G10 countries)

iv. Foreign (all other)

d. Gov’t Sponsored

e. Convertible

i. Investment grade

ii. Non-investment grade

Certificates of Deposit

a. U.S.

b. Foreign

Asset Backed Securities

a. Mortgage Backed Securities

i. Commercial Securitizations

A. Senior or higher

B. Mezzanine

C. Junior/Equity

ii. Commercial Resecuritizations

A. Senior or higher

B. Mezzanine

C. Junior/Equity

iii. Residential Securitizations

A. Senior or higher

B. Mezzanine

C. Junior/Equity

iv. Residential Resecuritizations

A. Senior or higher

B. Mezzanine

C. Junior/Equity

v. Agency Securitizations

A. Senior or higher

B. Mezzanine

C. Junior/Equity
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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vi. Agency Resecuritizations

A. Senior or higher

B. Mezzanine

C. Junior/Equity

b. CDO Securitizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

c. CDO Resecuritizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

d. CLOs Securitizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

e. CLO Resecuritizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

f. Credit Card Securitizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

g. Credit Card Resecuritizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

h. Auto-Loan Securitizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

i. Auto-Loan Resecuritizations

i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

j. Other
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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i. Senior or higher

ii. Mezzanine

iii. Junior/Equity

Repos

Reverse Repos 

DERIVATIVES Positive OTE Negative OTE

Total Derivatives

Futures 

a. Indices

i. Equity

ii. Commodity

b. Metals

i. Gold

c. Agriculture

d. Energy

i. Crude oil

ii. Natural gas

iii. Power

e. Interest Rate

f. Currency

g. Related to Financial Institutions

h. Other

Forwards

Swaps

a. Interest Rate Swap

b. Equity/Index Swap

c. Dividend Swap

d. Currency Swap

e. Variance Swap

f. Credit Default Swap

i. Single name CDS

A.Related to Financial Institutions

ii. Index CDS
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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iii. Exotic CDS

g. OTC Swap

i. Related to Financial Institutions

h. Total Return Swap

i. Other

OPTIONS Long Option Value Short Option Value

Total Options

Futures

a. Indices

i. Equity

ii. Commodity

b. Metals

i. Gold

c. Agriculture

d. Energy

i. Crude oil

ii. Natural Gas

iii. Power

e. Interest Rate

f. Currency

g. Related to Financial Institutions

h. Other

Stocks

a. Related to Financial Institutions

Customized/OTC

Physicals

a. Metals

i. Gold

b. Agriculture

c. Currency
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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d. Energy

i. Crude oil

ii. Natural gas

iii. Power

e. Other

FUNDS Long

Total Funds

Mutual Fund

a. U.S.

b. Foreign

NFA Listed Fund

Hedge Fund

Equity Fund

Money Market Fund

Private Equity Fund

REIT

Other Private funds

Funds and accounts other than private funds (i.e., the remainder 

of your assets under management)

ITEMIZATION

a. If the dollar value of any investment in any subcategory under the heading “Equities,” “Alternative 

Investments” or “Fixed Income” equals or exceeds 5% of the Pool’s Net Asset Value, itemize the 

investment(s) in the table below.

Subheading Description of 

Investment

Long/

Short

Cost Fair Value Year-to-Date 

Gain (Loss) 

b.If the dollar value of any investment in any subcategory under the heading “Derivatives” or “Options” equals or 

exceeds 5% of the Pool’s Net Asset Value, itemize the investment(s) in the table below.

Subheading Description of 

Investment

Long/

Short

OTE Counterparty Year-to-Date 

Gain (Loss)
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CFTC FORM CPO-PQR REPORT FOR COMMODITY POOL OPERATORS 

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c.If the dollar value of any investment in any subcategory under the heading “Funds” equals or exceeds 5% of 

the Pool’s Net Asset Value, itemize the investment(s) in the table below.

Subheading Fund Name Fund Type Fair Value Year-to-Date 

Gain (Loss)

– This Completes Form CPO-PQR –
69

OATH

BY FILING THIS REPORT, THE UNDERSIGNED AGREES THAT THE ANSWERS AND INFORMATION PROVIDED 

HEREIN are complete and accurate, and are not misleading in any material respect to the best of the undersigned’s 

knowledge and belief. Furthermore, by filing this Form CPO-PQR, the undersigned agrees that he or she knows that it 

is unlawful to sign this Form CPO-PQR if he or she knows or should know that any of the answers and information 

provided herein is not accurate and complete.

Name of the individual signing this Form CPO-PQR on behalf of the CPO:

Capacity in which the above is signing on behalf of the CPO: