On March 20, the Commodity Futures Trading Commission (CFTC) announced no-action relief (the “Letter”) for Commodity Pool Operators (CPOs). On March 23, the National Futures Association (NFA) issued a parallel Notice to Members (the “Notice”) that includes similar relief for Commodity Trading Advisors (CTAs). The Securities and Exchange Commission (SEC) previously offered relief on certain filings and other requirements.
Together, the Letter and the Notice provide the following COVID-19-related relief:
- CPO-PQR and CTA-PR: Both the CFTC and NFA have extended the deadlines for Form PQR filings. Annual filings will be due May 15. Quarterly filings for Q1-2020 will be due July 15. The normal deadlines would have been March 30 and May 30, respectively. CTAs are required to submit Form PR to the NFA on a quarterly basis. The deadline for Q1’s filing has been extended from May 15 to June 30.
- Pool Annual Reports: The deadline to file these with the NFA and distribute to pool participants is extended from March 30 to May 14.
- Periodic Account Statements: CPOs are required to distribute account statements to pool participants on either a monthly or quarterly basis. In either case, the deadline has been extended from 30 days to 45 days after the applicable period.
The Letter noted that, as COVID-19-related risks decrease, registrants should return to compliance with all regulatory obligations from which relief has been provided. The Letter is available here and the Notice is available here.