CFTC’s DSIO Issues Guidance for CCOs on Futures and Swap Dealer Annual Compliance Reports

CFTC Regulation 3.3 under the Commodity Exchange Act requires futures commission merchants, swap dealers and major swap participants (collectively, Registrants) to designate a qualified chief compliance officer (CCO), who must then prepare an annual compliance report (Report). The CFTC’s Division of Swap Dealer and Intermediary Oversight (DSIO) reviewed the Reports that CCOs submitted for the 2018 fiscal year and determined that it would be helpful to provide additional guidance to Registrants on the preparation of those Reports. Thus, the DSIO recently issued an advisory (Advisory) highlighting common deficiencies the staff identified in its review and providing recommendations for compliance with the requirements for the Reports. The Advisory does not address all aspects of the Report but “seeks to address those areas that present common and consistent challenges to a large proportion of Registrants.” This article highlights the key takeaways from the Advisory. For more on the Report requirements, see “CFTC Extends Annual Report Deadline for Futures Commission Merchants, Registered Swap Dealers and Major Swap Participants” (Apr. 9, 2015); and “CFTC Issues Guidance for Completing Annual CCO Reports of Swaps and Futures Firms” (Jan. 8, 2015).

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