CFTC Grants Two Non-U.S. Swap Dealers No-Action Relief from Annual CCO Reporting Deadline

The CFTC granted two swap dealers no-action relief from the timing requirements of annual reports by Chief Compliance Officers ("CCO Annual Reports") mandated by CFTC Rule 3.3(f)(2). The relief allows the swap dealers to file their reports by April 30, 2016 (rather than 90 days after their fiscal year end).

The CFTC granted the relief in part based on the fact that the home jurisdiction requirements of the swap dealers: (i) do not have a corresponding deadline for the applicable annual compliance report; (ii) address matters beyond the scope of the CCO Annual Report required of swap dealers pursuant to CFTC Rule 3.3(e); and (iii) consequently would require broad, enterprise-wide processes to produce the CCO Annual Report.