The Foley Adviser

Late Fee for NFA Forms PQR and PR Filings Effective Starting September 30, 2016

June 30, 2016

The National Futures Association recently amended NFA Compliance Rule 2-46 in order to impose late fees for its commodity pool operator (CPO) and commodity trading adviser (CTA) members that do not make quarterly filings on Forms PQR or PR on time. The fee will be $200 per business day that the applicable filing is late, starting for filings due on September 30, 2016. According to the explanation of the proposed amendment, the NFA is imposing the late fees due to a number of members who routinely fail to timely file. CPOs and CTAs are encouraged to review their filing procedures to ensure compliance in light of the new penalties, as the imposition of late fees will not otherwise preclude other disciplinary action by the NFA.