CFTC Issues No-Action Relief for Certain FCMs Concerning Annual Reports of CCOs
The CFTC's Division of Swap Dealer and Intermediary Oversight (DSIO) issued the attached no-action letter that provides certain FCMs with limited relief regarding the requirement that chief compliance officers of such FCMs prepare and submit an annual report, pursuant to CFTC Rule 3.3, as to fiscal years ending by March 31, 2013. The relief provided in the no-action letter is applicable to all FCMs that:
(1) were registered with the Commission as of June 4, 2012; and(2) are currently regulated by a U.S. prudential regulator or registered with the U.S. Securities and Exchange Commission (Covered Firms).
The no-action relief is subject to very numerous conditions as to the report that the CCO must file. That is, the no-action letter is not a general exemption from the CCO's preparation of his/her otherwise required report; it is only a reduction in the scope of the report.
See: CFTC Letter 12-47: Regulation 3.3; No-Action.