CFTC Issues No-Action Relief Regarding Electronic Reporting Requirements in OCR Final Rule (CFTC Letter 14-95)

The CFTC Division of Market Oversight ("DMO") issued a time-limited no-action letter that provides additional time for parties to comply with certain reporting requirements of the ownership and control final rule ("OCR Final Rule") under CFTC Rules Part 17, Part 18 and Part 20.

Specifically, DMO granted relief from the requirement to file trader identification and reporting forms electronically, and to provide certain additional information required by the OCR Final Rule. DMO stated that it issued the no-action relief to provide market participants additional time to build and test systems for purposes of complying with the electronic reporting and substantive requirements of the OCR Final Rule.

The OCR Final Rule, which was published in the Federal Register on November 18, 2013, requires the electronic submission of trader identification and market participant data on new and updated reporting forms. The reporting forms collect new information to better identify participants in futures and swaps markets. Reporting parties must begin to submit the forms electronically by August 15, 2014.

The relief provided in the letter will expire as follows:

• relief for submitting new form 102A and new form 102S will expire on February 11, 2015;
• relief for submitting new form 102B will expire on March 11, 2015; and
• relief for submitting new form 40/40S and new form 71 will expire on February 11, 2016.

See: CFTC Letter 14-95.Related news: CFTC Staff Will Host Training Calls on Implementation of Rules Governing Reporting of Ownership and Control Information (January 17, 2014) CFTC Publishes Final Rules on Ownership and Control Reports (Fed. Reg.) (November 18, 2013); CFTC to Hold Open Meeting to Consider Enhancing Protections for Futures Customers and Other Matters (October 24, 2013).