CFTC Rule Update: CTA Reporting Deadline for Form PR is February 14, 2013

Commodity Futures Trading Commission ("CFTC") Regulation 4.27 requires that all commodity trading advisers ("CTAs") registered with the CFTC and members of the National Futures Association ("NFA") must file a Form PR by February 14, 2013. The Form PR requires each CTA to report on annual basis general information about the CTA, trading programs, pool assets and the identity of the CPOs operating the pools. The NFA has provided its members with a Form PR template. The Form PR filing does not supersede the requirement to file a Form PF. Many SEC registered investment advisers will also be required to file their initial Form PF filings by April 30, 2013.

The first annual Form PR report for the year ended December 31, 2012 will be due by February 14, 2013 and must be filed electronically using NFA's EasyFile System accessed at http://www.nfa.futures.org/NFA-electronic-filings/easyFile-CTA-filers.HTML. The CTA's sec- urity manager must first set up security settings in order to access the EasyFile System.

The NFA has also proposed changes to NFA Compliance Rule 2-46 to require a CTA PR filing to be made quarterly within 45 days of the calendar quarter end. The first filing under this amendment is expected to be due for the quarter ending March 31, 2013. NFA will provide notice upon approval of the amendments.

Cheryl Spratt