See:Quote from Epic:
AFAIK, if you start the fund structure from day one and don't intend to use prior personal performance to market it, then such a disclosure of all prior trading history isn't required.
http://www.nfa.futures.org/nfa-compliance/publication-library/disclosure-document-guide.pdf
Page 36, specifically. You must disclose your past performance history, until you have 3 years of operating history for the fund itself.
This is the case for all registered commodity pools. Some (very shady) pools intentionally seek the QEP-only exemption from registration with the NFA, precisely because they want to avoid this requirement.