CPO and CTA Filing Requirements March 19, 2015 Tracey Hunt, Associate Director, Compliance Mary McHenry, Associate Director, Compliance Cesar Alvarez, Deputy Chief Compliance Officer, Lighthouse Partners

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 firm and NFA staff

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

 June 30, 2014 filing, Notice to Members I and I  September 30, 2014 filing, Notice to Members I  December 31, 2014 filing  March 31, 2015 filing  CFTC Staff Letter Recent Changes to Forms 5

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  To restart a relationship that was previously ended, new start date must be after previous end date, or firm will be unable to add the relationship (see next screen) Common Filing Deficiencies

 Relationships (cont’d) 7

 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  Trading manager relationship carries over between CPO PQR and CTA PR  Relationship Management screen Common Filing Deficiencies 8

 PQR includes pools that should not have a filing requirement  Discrepancies between current and prior filings (e.g. NAV or investments)  Reporting on programs in the CTA PR Common Filing Deficiencies 9

Transferring a Pool to Another CPO Transferring pools via the Questionnaire 10

11 Transferring a Pool to Another CPO Enter the name of the pool

Transferring a Pool to Another CPO 12

 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 13

Transferring a Pool to Another CPO 14

Transferring a Pool to Another CPO 15 Transferring pools via the Exemption System

 Search by pool name, similar to Questionnaire  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 on the Exemption Index  The Pool/Exemption Management screen allows the firm to end the co- CPO relationship Transferring a Pool to Another CPO 16

Transferring a Pool to Another CPO 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 NFA at Transferring a Pool to Another CPO 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 Annual Report Filing Requirements 19

 CFTC Letter No , Consolidation between Registered Investment Companies and Wholly Owned subsidiaries  Firm must update NFA records, in accordance with Notice to Members I  CFTC Letter No , Consolidation between Certain Commodity Pools and Wholly Owned Subsidiaries  Currently annually updated by NFA  Proposed exemption filing with NFA Consolidation 20

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

22  “ Ceased Trading” date Liquidation Statements

23  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

24  CFTC relief for CTA PR filing  Third-party recordkeeping rules  Fund-of-Fund guidance  Exemption/exclusion annual affirmation process  CFTC FAQs CPO and CTA Hot Topics

25  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

Thank you.