Commodity  Pool Operators (CPOs) are required to file certain information regarding their operations and their pools operation each quarter.  These requirements come from both the Commodities and Futures Trading Commission (CFTC) and the National Futures Association (NFA). Completion of Form CPO-PQR meets both the CFTC and the NFA’s rules*. The size of the CPO determines whether filing is required by the CFTC or NFA and Form CPO-PQR is a single filing to accommodate both regulators.

This filing requirement requires CPOs to provide portfolio, performance and risk information about their funds.


Came into effect: 2012

What needs to be filed?

Filing is required each Quarter as below:

Schedule CPO Size Filing
A All Quarterly - Within 15 days of the end of the quarter
B Mid-size Annually - Within 90 days of year end
B Large-size Quarterly - Within 15 days of the end of the quarter
C Large-size Quarterly - Within 15 days of the end of the quarter

Who is affected by this regulation?

All Commodity Pool Operators (CPO) are registered with the CFTC by application with the NFA and operate a commodity pool and solicit funds for the pool.

The filing defines the CPOs within 3 classifications based on size:

  • A Small-sized CPO is classified as having less than $150m in pool AUM (Asset Under Management) at the close of business during any day in the course of  a quarter.
  • A Mid-sized CPO is classified as having more than $150m in pool AUM at the close of business during any day in the course of  a quarter.
  • A Large CPO is classified as having at least $1.5b in pool AUM at the close of business during any day in the course of a quarter.

Insert table

CPOs AUM Schedules
Large-size CPOs A, B, C
Mid-size CPOs A, B
Small-size CPOs A, B

Note: Schedule B and Schedule C may not have to be filed with the CFTC if the CPO has completed certain sections of Form PF and meet other certain requirements.

Key points for consideration / what funds need to be reported?

CPO PQR covers a range of data that needs to be collated from multiple data systems these include:
Information on investment strategy, positions data, type’s of asset classes held, collateral, counterparty exposures and risk metrics.

Schedule A

Part 1

For all CPOs

  • Includes general identifying questions around the fund identification and key firm information.
  • Assets under management (AUM) and net AUM

Part 2

For each pool

  • General information
  • Third party admins, Brokers, Custodians, Auditors, Marketers
  • Monthly & annual performance
  • Subscription & redemption information

Schedule B

For each mid-sized & large CPO

  • Pool information (incl. strategies and investment techniques)
  • Top 5 counterparties by net counterparty credit exposure (to and from counterparty)
  • Trading and clearing practices
  • Value of pools derivatives positions
  • Detailed schedule of investments by type

Schedule C

Part 1

For only large CPOs
Aggregated information for the commodity pools:

  • List of investments by Geography
  • Portfolio Turnover

Part 2

For each Large Pool

  • Liquidity of portfolio
  • Pool counterparty credit exposure
  • Pool risk metrics
  • Pool borrowing information
  • Pool derivative positions and posted collateral
  • Pool financing liquidity
  • Information on pool investors
  • Duration of fixed income assets

How can UnaVista Assist?

  • Offers a complete view of your data with full data linage and audit trail to monitor exceptions and manage your regulatory filings.
  • UnaVista rules engine can assist in gathering information from multiple source systems and normalising, enriching, aggregating and transforming the data required to be reported.
  • Automated XML report generation and workflow and exception management helping clients validate their data, manage operational risk and stay compliant.
  • UnaVista regulatory hub combines all your regulatory reporting requirements within one platform.

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