CFTC No-Action Relief for Certain Swap Dealers Concerning Annual Reports of Chief Compliance Officers (Letter 13-32)

The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") issued the attached no-action letter which provides certain swap dealers ("SDs") with limited relief regarding the requirement that chief compliance officers of such SDs prepare and submit an Annual Report, pursuant to CFTC Rule 3.3.

The relief provided in the no-action letter is relevant only to firms that:

  1. Are not registrants of the SEC or regulated by a U.S. prudential regulator; and
  2. Ended their fiscal year on March 31, 2013 ("Covered Firms") (and thus which must file their CCO certification by July 31).

The no-action letter enumerates the subjects that must be addressed in the Annual Report of a Covered Firm for the fiscal year that ended on March 31, 2013. The letter also provides relief concerning the certification that a chief compliance officer must execute with respect to the Annual Report.

See: CFTC Letter 13-32.

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