On August 27, 2018, the Commodity Futures Trading Commission (“CFTC”) published final rules in the Federal Register amending its regulations regarding duties of chief compliance officers (“CCOs”) of swap dealers (“SD”), major swap participants (“MSPs”) and futures commission merchants (“FCMs”) (collectively, “Registrants”) and requirements for preparing, certifying and furnishing to the CFTC the annual report containing an assessment of these Registrants’ compliance activities. The overarching goals of the rule amendments are to make clarifications regarding the rules in light of the CFTC’s experience in administering them and harmonize the CFTC’s rules with similar rules of the Securities and Exchange Commission (“SEC”) applicable to security-based swap dealers. Specifically, the final rule amendments...

..Define the term “senior officer,” to whom CFTC rules require the CCO report directly in the alternative to reporting directly to the board of directors, as the Chief Executive Officer (“CEO”) or other equivalent officer, consistent with the SEC’s CCO rule...