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Commodity Futures Trading Commission • Office of Public Affairs • 202-418-5080

Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581

April 14, 2020

Fact Sheet: Notice of Proposed Rulemaking – Regulation 4.27 and Form CPO-PQR 

The Commodity Futures Trading Commission is proposing amendments to Commission Regulation 4.27 

and Form CPO-PQR, which implement the collection of data from certain registered commodity pool 

operators. This proposal, the development of which predated the COVID-19 pandemic, is the first 

substantive amendment to the regulation or the form since their adoption in 2012. The proposed 

amendments are intended to update Form CPO-PQR to better integrate the data collected through that 

form with other available data streams developed by the Commission since 2012 and to thereby, further 

enhance the Commission’s oversight of CPOs, their operated commodity pools, and their respective 

roles in the commodity interest markets. 

Major Themes for the Proposed Amendments to Regulation 4.27 and Form CPO-PQR

The proposed amendments are intended to enable the Commission to integrate its various sources of 

data regarding the operations of CPOs and their operated commodity pools while reducing the burden 

experienced by CPOs required to file Form CPO-PQR. The themes of the proposed rulemaking are as 

follows: 

More Focused Data Collection

• The amendments are designed to streamline the data collected from CPOs regarding their 

operated commodity pools without impacting the Commission’s ability to effectively oversee the 

commodity interest markets. 

• The changes would largely eliminate questions the answers to which are available to the 

Commission through other means, which further refocuses Form CPO-PQR on the data that has 

preliminarily been determined to be most useful.

Better Integrated Data Sets

• The changes would add questions to enable the data collected on Form CPO-PQR to be used 

conjunctively with other data regarding the commodity interest markets. For example, the 

proposed Revised Form CPO-PQR, with the addition of the legal entity identifiers for CPOs and 

pools that have them would enable the Commission to leverage other more frequent data sets 

regarding the swaps market in particular.

More Efficient Filings 

• The amendments would also permit CPOs to file the National Futures Association’s Form PQR in 

lieu of the Commission’s proposed Revised Form CPO-PQR, which reduces unnecessary filing 
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Commodity Futures Trading Commission • Office of Public Affairs • 202-418-5080

Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581

burden on Commission registrants and ensures that both the National Futures Association and 

the Commission have the information needed to satisfy their statutory responsibilities.

Request for Comment on Proposed Rule

The Commission invites comments on all aspects of the proposed rule and outlines specific questions 

for comment. Comments must be received on or before 60 days from the Commission’s Open Meeting 

on April 14, 2020 issuing the proposal. The public may submit comments, identified by “Amendments to 

Compliance Requirements for Commodity Pool Operators on Form CPO-PQR,” 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: Send to Christopher Kirkpatrick, Secretary of the Commission, Commodity Futures Trading 

Commission, Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581. 

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