Late in 2024 the CFTC updated the qualifications of a QEP. These updated qualifications go into affect March 26th, 2025. Please see below updated QEP (4.7 requirements):
The CFTC allows CTA’s the ability to file for exemption 4.7, however it limits their offering to QEP’s only. The CFTC qualifies an investor as a QEP or qualified eligible person if, one of the following are true:
- a natural person whose individual net worth, or joint net worth with that person’s spouse, at the time of either his purchase in the exempt pool or his opening of an exempt account exceeds $1,000,000
- a natural person who had an individual income in excess of $200,000 in each of the two most recent years or joint income with that person’s spouse in excess of $300,000 in each of those years and has a reasonable expectation of reaching the same income level in the current year
If an investor falls into one of the above requirements, it will also need to meet the portfolio requirement in order to be considered a QEP. The portfolio requirement can be met in one of three ways:
- Owns securities and other investments with an aggregate market value of at least $4 million;
- Has had on deposit with an FCM at least $400,000 in exchange-specified initial margin and option premiums for commodity interest transactions, together with required minimum security deposit for retail forex transactions, in the six months prior to the investment; OR
- Has a combination of the two above. For example, has $2 million in securities/investments and $200,000 in exchange-specified initial margin in the six months prior to the investment