Alert September 24, 2013

NFA Requires CTAs to Report on a Quarterly Basis

The National Futures Association (the “NFA”) announced that amendments to Compliance Rule 2-46 that require commodity trading advisors (“CTAs”) to report to the NFA on a quarterly basis will be effective beginning with the quarter ending September 30, 2013.  This obligation is in addition to the pre-existing requirement included in CFTC Rule 4.27, which mandates that CTAs file with the NFA an annual report on Form CTA-PR.

The amended NFA rule requires CTAs to file reports on NFA Form PR on a quarterly basis within 45 days of the end of the calendar quarters ending in March, June, and September of each year; a year-end report is required to be submitted within 45 days of the calendar year end.  The NFA Form PR consists of the CFTC’s Form CTA-PR plus additional questions pertaining to certain trading programs offered by the CTA.  The year-end report on NFA Form PR will satisfy the CFTC’s annual filing requirement.

The first report under the amended rule, for the quarter ending September 30, 2013, will be due on November 14, 2013.  All CTAs that are members of the NFA must submit the required form each quarter even if they are not currently active.

The NFA will host a webinar on October 3rd to discuss the new requirements.