SIFMA and ISDA appreciate the opportunity to provide the Commodity Futures Trading Commission ("CFTC" or "the Commission") with comments on its proposed…
Mr. Christopher Kirkpatrick
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Center
1155 21st Street NW.
Washington, DC 20581
Re: Chief Compliance Officer Duties and Annual Report Requirements for Futures Commission Merchants, Swap Dealers, and Major Swap Participants; Amendments (RIN 3038-AE56)
Dear Mr. Kirkpatrick:
The Futures Industry Association (“FIA”) and Securities Industry and Financial Markets Association (“SIFMA”) are pleased to submit this letter in response to the proposal (the “Proposal”)3 by the Commodity Futures Trading Commission (“Commission”) regarding chief compliance officer (“CCO”) duties and annual report requirements for futures commission merchants (“FCMs”), swap dealers (“SDs”), and
major swap participants (“MSPs”) (collectively, “Registrants”) set forth in Commission Regulations § 3.3 (“Rule 3.3”). We support the efforts of the Commission and its staff to review and revise Rule 3.3 with a view to promoting consistency (where appropriate) with parallel requirements adopted by other regulators, reducing undue regulatory burdens, and improving regulatory oversight.