CPO and CTA Filing Requirements October 23, 2014 Tracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance Ken Desplaines, Lighthouse Investment Partners Ken Wu, Oppenheimer Funds

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

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

5  Effective for June 30 th PQR Filings  Additional help text in Steps 2a and 2b Recent Changes to Forms  Only include pools for which the CPO is required to be registered

6  Effective for June 30 th PQR Filings  New question: Box 30 Recent Changes to Forms  Include all commodity pools, even those exempt under 4.13 or excluded under 4.5

Recent Changes to Forms New Questions - Boxes breakdown the total in Box 30

8  Effective for June 30 th PQR Filings  Expanded help text in Step 5 Recent Changes to Forms

9  Effective for June 30 th Form PR Filings  Additional help text in Step 1d Recent Changes to Forms  Include only trading programs for which the CTA is required to be registered

10  Effective for June 30 th Form PR Filings  Additional help text in Steps 2a and 2b Recent Changes to Forms  Exclude any assets that are attributable to pools for which the CPO is not required to be registered  Exclude any assets that are attributable to pools that you operate as a CPO

11  Effective for June 30 th PR Filings  Additional help text in Step 3 Recent Changes to Forms

12  Effective for June 30 th PR Filings  New question - Step 8 (Box 30) Recent Changes to Forms  Include all managed accounts, even those for commodity pools that are exempt or excluded pursuant to 4.13 or 4.5  Boxes breakdown the total in Box 30

13  Effective for September 30 th PQR Filings  Added boxes 8501 and 8502 to Fixed Income section of the Schedule of Investments Recent Changes to Forms

14  Effective for September 30 th PQR Filings  Additional help text was added to Step 10, Statement of AUM regarding the use of base currencies and conversion factors Recent Changes to Forms

15  Effective for September 30 th PQR Filings  Additional relationship information for certain steps will persist from quarter to quarter Recent Changes to Forms

16  Relationship start and end dates  Relationships across firms and/or forms  Pools appear on a PQR that should not be filing  Discrepancies between current and prior filings (e.g. NAV or investments)  Responding to NFA Staff inquiries Common Filing Deficiencies

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

18  “ Ceased Trading” date Liquidation Statements

19  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

20  NFA’s website,  Form PQR and Form PR templates updated quarterly  2014 Tutorial, “Common PQR Filing Deficiencies”  2013 Webinar, “Quarterly Reporting Requirements for CTAs”  Technical Support    NFA’s Information Center  (800) , or  (312) Resources

21  CPO delegation  Third-party recordkeeping rules  Fund-of-Fund guidance  Consolidation of statements  Exemption/exclusion annual affirmation process  Possible CPO and CTA customer protection measures CPO and CTA Hot Topics

Thank you.