Response to CFTC Proposed Rulemaking on Form CPO-PQR

On June 15, MFA submitted a letter to the CFTC in response to proposed rulemaking on Form CPO-PQR.  The letter strongly supports revising Form CPO-PQR so regulators can make better use of data collected, stop collecting data that has not been useful and reduce the reporting burden for market participants. In the letter, MFA makes three key recommendations to improve the reporting process and ensure data protection:

  1. Incorporate alphanumeric identifiers in Form CPO-PQR to mitigate potential cyber breaches, and require registrants to separately report LEIs and CPO and pool identifying information.
  2. Amend the Schedule of Investments to Align with NFA’s 2010 Form PQR.
  3. Amend Form CPO-PQR Instructions to include FAQs provided by the Commission and NFA.


Please find attached a copy of our letter.  Let me know if you have questions or comments.