Comment Text:
The Alternative Investment Management Association Limited (AIMA) appreciates the opportunity
to submit its comments to the Commodity Futures Trading Commission’s (CFTC) proposed rule
and form changes contained in the notice of proposed rulemaking entitled “Amendments to
Compliance Requirements for Commodity Pool Operators on Form CPO-PQR” (the ‘Proposing
Release’).
AIMA’s global membership includes many domestic and non-U.S. commodity pool operators
(‘CPOs’) registered with the CFTC who are also members of the National Futures Association (NFA) and so are subject to the Form CPO-PQR and Form PQR reporting requirements. More often than not, these CPOs are also registered investment advisers and subject to the Securities and
Exchange Commission’s filing requirements on Form PF with respect to their commodity pools
that are private funds as a consequence. Many of these CPOs are also subject to similar reporting
requirements in one or more other countries as well
Our detailed comments can be found in the attached letter.
