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Alternative Market Briefing

Dechert alerts registered CTAs on new NFA quarterly filing requirements

Thursday, September 19, 2013

Beverly Chandler, Opalesque London:

Dechert reports that the U.S. National Futures Association (NFA) has announced its new quarterly filing requirement for commodity trading advisors (CTAs). Dechert explains that such requirement will begin with the reporting of third quarter 2013 data (i.e., September 30, 2013) for all CTAs that are registered with the U.S. Commodity Futures Trading Commission (CFTC) and members of the NFA. The firm writes: "The filing requirement under NFA Compliance Rule 2-46 (NFA Form PR) apply to all CTAs regardless of whether they are currently active. The first NFA Form PR filing will be due November 14, 2013."

CTAs are already subject to a similar CFTC filing requirement in the form of the CFTC’s Form CTA-PR, an annual filing required within 45 days of the end of each calendar year (i.e., by February 14). On initial review, Dechert finds that NFA Form PR contains more questions and requires additional data beyond what is required on CFTC Form CTA-PR. The firm writes: "Therefore, as third quarter-end approaches, CTAs must familiarize themselves with the form and instructions, be cognizant of the type of data needed in order to comply with this new risk reporting obligation, and be in a position to collect and sort such data to facilitate filing NFA Form PR." The firm offers a sample NFA Form PR template.

Dechert reports that it will be studying the new form, listening in ......................

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