CFTC amendments to rules concerning chief compliance officer ("CCO") duties and certain annual report requirements were published in the Federal Register. The amendments will be effective September 26, 2018.
As previously covered, the amendments to Rules 3.1 and 3.3 will (i) define the term "senior officer," (ii) clarify the responsibilities of a CCO employed by a futures commission merchant, swap dealer or major swap participant, and (iii) modify the content and submission requirements of a CCO annual report. Additionally, a number of the amendments introduce a "reasonableness" standard, rather than a strict liability standard, on the activities of the CCO.
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