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CFTC Relief Update Part 3

March 23rd | 2020



The CFTC released a third wave of relief to market participants in response to COVID-19. The relief consists of two additional no-action letters, issued by the Division of Swap Dealer and Intermediary Oversight (DSIO), that provide temporary, targeted relief to a large U.S. entity that helps finance America’s oil and gas sector and to those who operate commodity-focused investment funds the CFTC regulates. Private funds that are CPOs should pay special attention to this one because one of the CFTC staff letters indicate no-action relief as long as the conditions deadlines below are met.


Filing of Form CPO-PQR under Commission regulation 4.27.


  • Small or Mid-Sized CPO annual reports on Form CPO-PQR by May 15, 2020.

  • Large CPO quarterly report on Form CPO-PQR for Q1 2020 by July 15, 2020.


Pool Annual Reports under Commission Regulations 4.7(b)(3) and 4.22(c).


Any requirement that a CPO with a pool annual report due on or before April 30, 2020 file such report pursuant to Commission regulations 4.7(b)(3) or 4.22(c), provided that the annual certified financial statements for its operated commodity pools are filed with the National Futures Association and distributed to pool participants no later than 45 days after the due date for such report.


  • This does not foreclose a CPO from requesting an additional extension of time not to exceed a total of 180 days from the end of the pool’s fiscal year consistent with Commission regulation 4.22(f). This relief does not foreclose a CPO from requesting an additional extension of time not to exceed a total of 180 days from the end of the pool’s fiscal year consistent with Commission regulation 4.22(f).


Pool Periodic Account Statements under Commission Regulations 4.7(b)(2) or 4.22(b).


If a CPO distributes periodic account statements to pool participants on either a monthly or quarterly basis, such statements must be distributed to participants within 45 days of the end of the reporting period for all reporting periods ending on or before April 30, 2020.

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