The NFA recently approved NFA Compliance Rule 2-46 which will introduce new quarterly reporting requirements for certain registered CPOs. Back in May 2009 the NFA sought comments from CPOs on a proposal to modify the NFA’s web-based disclosure document system. The proposal was aimed at requiring CPOs to report limited pool performance and operational data for all their listed pools to the NFA on a quarterly basis. Our expectation is that the NFA will be requiring such quarterly reporting for any commodity pools for which the CPO has reporting requirements under CFTC Rule 4-22. Taking this a step further, we are of the view the NFA Compliance Rule 2-46 will prompt quarterly reporting for pools operated pursuant to CFTC Rule 4.7, but it will NOT require information to be filed for pools which claim exemption pursuant to Rule 4.13 (e.g., 4.13(a)(3) or 4.13(a)(4)). Read the rest of this entry »
