1. CPO and CTA Filing Requirements March 5, 2015 Tracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance

2. 2 Pool Quarterly Reports and Form PR  Form and Process  CFTC Form  Process for making changes  How Help Text is developed

3. 3 Pool Quarterly Reports and Form PR  NFA’s review and use of PQRs and PRs  Compliance Department Structure  Risk Analysis  Relationship Data  ROR vs. Net Income  Conversations between CPO and NFA Staff

4. 4  Managing a firm’s regulatory filings  Role of Compliance and other groups/areas  Process  Documenting assumptions  Reconciliations  Responding to NFA Staff inquiries CPO’s Approach to Filings

5.  June 30, 2014 filing, Notice to Members I-14-13 and I-14-15  September 30, 2014 filing, Notice to Members I-14-26  December 31, 2014 filing  March 31, 2015 filing  CFTC Staff Letter 14-115 Recent Changes to Forms 5

6. 6  Relationships  Maintain records of the start and end dates for the various relationships  Firms can change start dates, but only NFA can change end dates  Trading manager relationship carries over between CPO PQR and CTA PR  To restart a relationship that was previously ended, new start date must be prior to previous end date, or firm will be unable to add the relationship; see next screen Common Filing Deficiencies

7.  Relationships (cont’d) 7

8.  End date should be prior to reporting date if you want to remove it from that filing, i.e. if a pool incorrectly appears on the 12/31/14 CTA PR, the relationship should be ended using a date prior to 12/31/14  Relationship Management screen Common Filing Deficiencies 8

9.  PQR includes Pools that should not have a filing requirement  Discrepancies between current and prior filings (e.g. NAV or investments)  Responding to NFA staff inquiries Common Filing Deficiencies 9

10.  Members transfer pools via the Questionnaire or Exemption system  In the Questionnaire System, there is the ability to add pools under the Firm’s Pool List  Once the pool is selected, it will appear in your pool list  The previous CPO can now delete the pool via the questionnaire, and indicate that it no longer operates the pool Transferring a Pool to another CPO 10

11. Transferring a Pool to another CPO Questionnaire System 11

12. Transferring a Pool to another CPO 12

13. Transferring a Pool to another CPO 13

14.  In the Exemption System, the new CPO can add the pool to its list by selecting “Create a co-CPO relationship” and searching for the applicable pool  Once the pool is selected, it will be added to the firm’s list and the Co- CPO column will include “View Firms”  Now the previous firm can remove itself as a co-CPO by selecting the applicable pool  The Pool/Exemption Management screen allows the firm to end the co- CPO relationship Transferring a Pool to another CPO 14

15. Transferring a Pool to another CPO 15

16. Transferring a Pool to another CPO 16

17.  Exemptions do not always carry over and must be filed by each CPO, as applicable  Do not create a new pool—the historical information will not transfer  If the transfer involves a non-member, you must email NFA at exemptions@nfa.futures.org exemptions@nfa.futures.org Transferring a Pool to another CPO 17

18.  New cover page in EasyFile  Required questions specific to the pool and its operations  One new Key Financial Balance, Redemptions Receivable from Other Funds  NFA Notice to Members I-15-09 Annual Report filing requirements 18

19.  CFTC Letter No. 13-51, Consolidation between Registered Investment Companies and Wholly Owned subsidiaries  Firm must update NFA records, in accordance with Notice to Members I-13-36  CFTC Letter No. 14-112, Consolidation between Certain Commodity Pools and Wholly Owned Subsidiaries  Currently annually updated by NFA  Proposed exemption filing with NFA Consolidation 19

20. 20  Update the Annual Questionnaire to delete or cease a pool, and provide specifics Liquidation Statements

21. 21  “ Ceased Trading” date Liquidation Statements

22. 22  Impact on PQRs  Disclosure to pool participants  Audited by CPA unless waivers are obtained  Required components of a liquidation statement  Circumstances that do not represent a “liquidated pool”  Switching from 4.7 to 4.13 exempt pool  Ceased trading commodity interests  Temporary cessation of trading  Other regulatory requirements other than CFTC Liquidation Statements

23. 23  CFTC relief for CTA PR filing  Third-party recordkeeping rules  Fund-of-Fund guidance  Exemption/exclusion annual affirmation process  Possible CPO and CTA customer protection measures  CFTC FAQs CPO and CTA Hot Topics

24. 24  NFA’s website, www.nfa.futures.orgwww.nfa.futures.org  Form PQR and Form PR templates updated quarterly  2014 Tutorial, “Common PQR Filing Deficiencies”  2013 Webinar, “Quarterly Reporting Requirements for CTAs”  Technical Support  PQRsupport@nfa.futures.org  PRsupport@nfa.futures.org  NFA’s Information Center  (800) 621-3570, or  (312) 781-1410 Resources

25. Thank you.