The National Futures Association instituted a procedure to ensure that commodity trading advisors that solely direct trading of pools for which the firm operates as a registered or exempt commodity pool operator do not have to file a Form PR. This prior requirement was eliminated through recent amendment of a rule by the Commodity Futures Trading Commission (click here to access Rule 4.27). By March 31, 2020, all relevant firms should log into the CTA Annual Questionnaire and answer “no” to the question “Does the firm currently direct any trading of commodity interest accounts?” and then click “Submit Filing.” (Click here for access to NFA’s CTA Annual Questionnaire.)