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You Asked They Answered: The CFTC Publishes Updated FAQ for Form CPO-PQR | K&L Gates LLP

Introduction On 26 May 2021, the Commodity Futures Trading Commission’s (CFTC or the Commission) Market Participants Division (MPD) published updated responses to frequently asked questions regarding Form CPO-PQR and CFTC Regulation 4.27 (the 2021 FAQ). The purpose of the 2021 FAQ is to provide guidance to commodity pool operators (CPOs) filing the recently revised Form CPO-PQR. 1 Form CPO-PQR is a filing designed to collect data from registered CPOs 2 about each of their operated commodity pools. CFTC Regulation 4.27 requires that CPOs file Form CPO-PQR with the National Futures Association (NFA). 3 The Commission began requiring CPOs to file Form CPO-PQR in 2012. 4 On 6 October 2020, the Commission adopted a final rule that amended CFTC Regulation 4.27 and Form CPO-PQR (the 2020 Final Rule).

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