CFTC Extends Large Trader Reporting Compliance Date for FCMs and DCMs

The CFTC Division of Market Oversight granted no-action relief to futures commission merchants, clearing members, foreign brokers, and designated contract markets, by extending the compliance date for amended large trader reporting requirements.

The relief was a response to a request by the Futures Industry Association ("FIA") that warned about the requirements' effect on vendor development, testing schedules, compliance program timelines, data ingestion and market surveillance planning as well as coordination among participants. 

The FIA requested the extension until 18 months after the CFTC completes three implementation milestones: commencing public implementation calls, opening the CFTC Portal for testing, and publishing a revised Part 17 Guidebook.

The FIA noted that the CFTC Portal still had not opened for testing more than "six months after publication of the Final Rule," preventing firms from receiving the approximately 18 months of testing time anticipated in the rule's preamble. The Final Rule, published June 3, 2024, amended Part 17 ("Information to be furnished by futures commission merchants, clearing members and foreign brokers") regulations to modify the data submission standard and data elements for large trader position reports required under regulation 17.00(a), with an original compliance date of June 3, 2026.

As a condition of the no-action position, covered firms must continue to submit reports in accordance with the Part 17 requirements that were in effect on June 2, 2024.