The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Company Institute (ICI) provide confirmation to the National Futures Association (NFA) regarding the application of NFA Compliance Rule 2-46 to Commodity Pool Operators (CPOs) of registered investment companies (registered funds) that trade in commodity interests through wholly-owned subsidiaries (known as controlled foreign corporations or CFCs). Specifically, SIFMA AMG and ICI request that NFA confirm that CPOs to registered funds that consolidate the CFC with the registered fund for financial reporting purposes may defer the reporting obligation under Compliance Rule 2-46 for the CFC until the first applicable reporting period ending after the compliance date of the Commodity Futures Trading Commission (CFTC’s) final harmonization rule.

The groups also sent a letter on the issue to the CFTC on April 10, 2013.