CFTC Staff Letter 14-154: Extension of Time to Furnish 2014 Annual Reports

U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre
1155 21st Street, NW, Washington, DC 20581
Telephone: (202) 418-5000
Division of Swap Dealer and
Intermediary Oversight
Thomas J. Smith
Acting Director
CFTC Letter No. 14-154
No-Action
December 22, 2014
Division of Swap Dealer and Intermediary Oversight Re: Time Limited No-Action Relief for Futures Commission Merchants, Swap Dealers, and Major Swap Participants from Compliance with the Timing Requirements of Commission Regulation 3.3(f)(2) Relating to Annual Reports by Chief Compliance Officers Ladies and Gentlemen:
The Division of Swap Dealer and Intermediary Oversight (“Division”) of the Commodity Futures Trading Commission (“Commission”) is providing time-limited no-action relief from the time requirements for submitting an annual report set forth in Commission Regulation 3.3(f)(2), 1 by futures commission merchants (“FCMs”), swap dealers (“SDs”), and major swap participants (“MSPs”). The relief applies to the timing for submitting an annual report for a registrant that has a fiscal year ending on or before January 31, 2015. Regulatory Background
Section 731 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(“Dodd-Frank Act”) 3 added Section 4s(k) to the Commodity Exchange Act (“CEA”), 4 which requires each SD and MSP to designate an individual to serve as its CCO, who must perform the duties and responsibilities required by Commission Regulations. In addition, section 732 of the