On July 23, 2015, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued a letter (dated July 21, 2015) that exempts commodity trading advisors that are registered but do not direct any trading of client commodity interest accounts from filing Form CTA-PR. The letter describes the DSIO’s reasoning that requiring a CTA does not direct any client commodity interest accounts to file a Form CTA-PR would provide little additional information regarding that CTA beyond that already available to the CFTC as part of the registration process and the CTA’s ongoing obligations as a registrant. Accordingly, the letter provides an exemption for these registrants from the reporting provisions of CFTC Regulation 4.27(c).

CFTC Staff Letter 15-47 is available at: http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/15-47.pdf