CCO Annual Report Requirements for FCMs, SDs and Major Swap Participants; Amendments to Filing Date

Published on:
September 16, 2016
Submitted to:
CFTC
Submitted by:
SIFMA, FIA, ISDA

Summary

SIFMA, FIA, and ISDA are pleased to submit this letter on behalf of their futures commission merchant and provisionally registered swap dealer and major swap participants member firms, in connection with the proposal of the Commodity Futures Trading Commission to codify current no-action relief4 by amending the requirements of Rule 3.3 (f)(2) of the regulations promulgated under the Commodity Exchange Act (the “CEA”).

Excerpt

Mr. Christopher Kirkpatrick

Secretary to the Commission

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

Re: Chief Compliance Officer Annual Report Requirements for Futures Commission Merchants, Swap Dealers and Major Swap Participants; Amendments to Filing Date (RIN 3038 – AE49)

Dear Mr. Kirkpatrick

The Futures Industry Association (the “FIA”)1, International Swaps and Derivatives Association (“ISDA”)2 and Securities Industry and Financial Markets Association (“SIFMA”)3 (the “Associations”), are pleased to submit this letter on behalf of their futures commission merchant (“FCM”) and provisionally registered swap dealer (“SD”) and major swap participants (“MSP”) member firms (collectively “Registrants”), in connection with the proposal of the Commodity Futures Trading Commission (the “Commission” or the “CFTC”) to codify current no-action relief4 by amending the requirements of Rule 3.3 (f)(2) of the regulations promulgated under the Commodity Exchange Act (the “CEA”).

The Associations greatly appreciate the efforts of the Commission to improve the process for filing the Chief Compliance Officer Annual Report (“CCO Annual Report”). As discussed in greater detail below, we do, however, have certain recommendations to improve the proposal. Specifically, our comments reflect concerns regarding: (i) linking the filing date of the CCO Annual Report to the submission of the Registrants’ annual financial reports (including, but not limited to, Form 1-FR-FCM or FOCUS Report) for US Registrants or Registrants for which there is no comparability determination; and (ii) establishing a 15 day deadline to file the comparable Annual Report (“Comparable Annual Report”) with the Commission following the completion date of this report for Registrants that are subject to a substituted compliance determination (“Substituted Compliance Registrants”).

Continue Reading >

Details

Download

More Content

  • Letters
    Oct 22, 2026

    Treasury/IRS Notice 2026-49: Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers

    SIFMA supports modernizing retirement plan rollovers through standardized electronic processes, fraud safeguards and appropriate implementation timelines.
  • Amicus Briefs
    Oct 21, 2026

    In re USD LIBOR Litigation

  • Letters
    Oct 20, 2026

    SEC’s Proposed Rule Regulation Crypto Assets

    SIFMA and SIFMA AMG provide recommendations to the SEC on its proposed crypto asset regulation, addressing regulatory clarity, implementation and investor protection.

Get the latest trends, stats, and research on financial markets and securities.