National Futures Association (NFA) has issued a notice requiring all commodity pool operators (CPOs) that have filed a notice of claim under Commodity Futures Trading Commission Letter No. 14-112 to submit an additional notice with respect to each such claim through NFA’s electronic Exemption System by no later than July 31. NFA is requiring these supplemental NFA notice filings in an effort to ensure that its records are accurate for purposes of applying CFTC financial reporting requirements to such CPOs. CFTC Letter No. 14-112, which was issued by the CFTC’s Division of Swap Dealer and Intermediary Oversight (DSIO) in September 2014, permits a CPO of a commodity pool that wholly owns one or more subsidiary pools to consolidate the annual report and Form CPO-PQR filings for the parent and subsidiary pools into a single filing (rather than filing separate reports for each pool), provided that the CPO complies with certain conditions set out in the letter and files a notice of claim with DSIO.

In order to file the supplemental notices with NFA, affected CPOs should first ensure that any parent commodity pool and its wholly owned subsidiary pools have been appropriately identified as such on the CPO’s Annual Questionnaire through NFA’s website.

More information on the NFA filing process, including detailed instructions and a link to NFA’s Exemption System, is available here.