NFA has proposed late fees of approximately $200 per business day for late Form PQR filings applicable to CPOs and late Form PR filings for CTAs.   The late fees are being proposed as a deterrent to an increase in the number of late filings.  For late Form PQRs, late fees are proposed to apply to the CPO entity and not each pool operated by the CPO.  In addition, the imposition of late fees will not preclude NFA from initiating disciplinary actions against a CPO or CTA for late filings. 

NFA Compliance Rule 2-46 requires that each CPO must file Form PQR on a quarterly basis with NFA within 60 days after the end of the March, June and September quarters, and a year-end report within 90 days of the calendar year-end.  Similarly, CTAs are required to file Form PR on a quarterly basis with NFA within 45 days after the end of the March, June and September quarters, and a year-end report within 45 days of the calendar year-end.  CPOs first began filing Form PQR in 2010 while CTAs began filing Form PR in 2013.  In its proposal issued on May 31, 2016, NFA requested that the proposal become effective 10 days after receipt of the submission to the CFTC.