Designation of a Chief Compliance Officer; Required Compliance Policies; and Annual Report of a Futures Commission Merchant, Swap Dealer, or Major Swap Participant

SIFMA and the Futures Industry Association (FIA) provide comments to the Commodity Futures Trading Commission (CFTC) on proposed rules relating to the designation of a chief compliance officer (CCO); required compliance policies; and annual report of a futures commission merchant (FCM), swap dealer (SD), or major swap participant (MSP).  The proposals would implement certain requirements included in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and amend the Commodity Exchange Act (CEA).  The groups request that the CFTC consider republishing any changes in the proposal for a short additional comment period.  The groups share their concerns that the proposed rules would: 1) establish a significantly different compliance framework from the current regulatory system; and 2) exceed the Dodd-Frank Act’s mandate with respect to regulations relating to the duties of CCOs.  The groups offer their expertise, observations and recommendations for the proposed rule.  In addition, the groups filed supplemental comments with the CFTC on June 3, 2011.