CPBG failed to file one or more of its commodity pools’ annual reports with the NFA in a timely manner. CPBG is required to file its commodity pools’ annual reports with the NFA no later than 90 days from the close of the pools’ fiscal year, which can be extended by the NFA for not more than an additional 90 days. CPBG failed to file timely reports despite having received grants of extension from NFA. CPBG is a registered CPO for pools that operate as funds-of-funds; all pools CPBG operated were employee benefit pools.
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