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National Futures Association Proposes Late Filing Fee for NFA Form PQR and Form PR

The National Futures Association (NFA) has proposed an amendment to NFA Compliance Rule 2-46 that would add a late filing fee of $200 for each business day that NFA Form PQR or Form PR is filed after the applicable deadline. NFA Form PQR and Form PR are required to be filed with the NFA on a quarterly basis by registered Commodity Pool Operators (CPOs) or Commodity Trading Advisors, respectively. For late NFA Form PQRs, the fee will apply at the CPO level and will not be assessed separately for each pool operated by the CPO that has a late filing.

The NFA intends to make the proposed amendment effective ten days after May 31, 2016, unless the Commodity Futures Trading Commission notifies the NFA that it has determined to review the proposals for approval.

The NFA rule submission is available here.

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About this Author

Christian B. Hennion, Finance Attorney, Katten Muchin Law Firm
Associate

Christian B. Hennion concentrates his practice in financial services and asset management matters, including counseling fund managers, registered investment advisers and commodity trading advisors on both transactional and regulatory matters. Chris has advised a wide range of US and international managers, from start-ups to large institutions, regarding a variety of matters, including private fund launches and reorganizations, advisory engagements, Investment Advisers Act and Commodity Exchange Act compliance obligations, Securities and Exchange Commission (SEC) and Commodity Futures...

312-902-5521
Associate

Timothy Kertland concentrates his practice on transactional, corporate and regulatory aspects of financial services matters. Timothy is able to provide legal services to a wide variety of clients including proprietary trading firms, hedge funds, broker-dealers, registered investment advisers, and commodity trading advisers.

While in law school, Timothy served as an editor of the Virginia Tax Review. As a first-year law student, he represented the University of Virginia School of Law at the National Transactional LawMeets Competition.

312-902-5343