CFTC Issues No-Action Letter to Mitsui Regarding Chief Compliance Officer Annual Reporting Requirements (CFTC Letter 14-32)

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") provided no-action relief to Mitsui Company Precious Metals, Inc. (“Mitsui”) regarding the annual reporting requirements for chief compliance officers ("CCOs") pursuant to CFTC Rule 3.3 ("Chief Compliance Officer").

In the letter, the CFTC found that given that Mitsui's fiscal year ends on March 31, 2014, and it was only required to register as a swap dealer as of the preceding December 31, it would not provide enough time to prepare and submit a full annual report under CFTC Rule 3.3. The letter allows the CCO to provide an abbreviated certification with respect to the prior three-month period.

See: CFTC Letter 14-32.See also: CFTC Issues Two No-Action Letters Regarding CCO Reporting Requirements (CFTC Letters 13-84 and 13-85) (with Lofchie Comment) (December 31, 2013); CFTC No-Action Relief for Certain Swap Dealers Concerning Annual Reports of Chief Compliance Officers (Letter 13-32) (June 26, 2013).