CFTC, NFA Announce COVID-19 Relief for CPOs and CTAs

CFTC, NFA Announce COVID-19 Relief for CPOs and CTAs

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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.

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Darren Mooney

Partner and Co-Head of Business Development

Darren Mooney is a Partner and the Co-Head of Business Development at Greyline. Before joining Greyline, Darren served as deputy chief compliance officer of Partner Fund Management where he held primary responsibility for the compliance program of the second-largest hedge fund in the Bay Area. Prior to that, Darren spent five years providing compliance consulting services at Cordium and then ACA Compliance Group, where he led the company’s San Francisco office and west coast operations. In addition to providing ongoing consulting services to a variety of investment managers, including hedge fund, private equity, venture capital, real estate, quantitative and other wealth managers, Darren also regularly guided clients through the SEC registration process, implemented tailored compliance programs, supported clients’ live SEC exams, and served as an SEC-mandated independent compliance consultant following an SEC enforcement action. Darren’s other experience includes serving as deputy chief compliance officer and associate counsel at F-Squared Investments where he directly supported the compliance program during the investigation and subsequent enforcement regarding historical advertising practices. Darren has a B.S. in Economics from the University of Delaware and a J.D. from Suffolk University Law School. He is a member of the Massachusetts bar.

Annie Kong

Partner and Head of Venture Capital
Annie Kong is a Partner and Head of the Venture Capital Division at Greyline. She provides ongoing compliance consulting to investment advisers and manages client relationships. Prior to joining Greyline, Annie was part of compliance and operations at a long-only manager-of-managers that advised pension fund clients. While there, she conducted compliance and operational due diligence on SEC-registered investment advisers on the platform. She also oversaw and counseled on various legal matters across the firm. Annie has a B.A. in Economics from the University of California, San Diego, and a J.D. from the University of San Diego School of Law. She is an active member of the State Bar of California.
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