ARTICLE
16 April 2015

US Commodity Futures Trading Commission Staff Issues No-Action Position Regarding Timing For Submission Of Chief Compliance Officer Annual Reports

SS
Shearman & Sterling LLP

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CFTC Regulation 3.3(f) requires FCMs, SDs and MSPs to submit to the CFTC annual reports by Chief Compliance Officers not more than 60 days after the end of their fiscal year.
United States Finance and Banking
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On March 27, 2015, the US Commodity Futures Trading Commission issued a no-action letter to futures commission merchants, swap dealers and major swap participants that provides relief from certain requirements under CFTC Regulation 3.3(f). CFTC Regulation 3.3(f) requires FCMs, SDs and MSPs to submit to the CFTC annual reports by Chief Compliance Officers not more than 60 days after the end of their fiscal year. The relief grants FCMs, SDs and MSPs an additional 30 days to provide such annual reports to the CFTC. The relief will remain in effect until the adoption of a rule or rule amendment that modifies the timing requirements of CFTC Regulation 3.3(f)(2) and provides that the CFTC retains the authority to condition further, modify, suspend, terminate, or otherwise restrict the terms of the no-action relief provided, in its discretion.

CFTC Staff Letter No. 15-15 is available at: http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/15-15.pdf.

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