The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued two no-action letters providing relief from certain chief compliance officer (CCO) annual report filing requirements.Pursuant to No-Action Letter No. 13-84, DSIO will allow futures commission merchants, swap dealers (SDs), major swap participants and CCOs of such firms up to 90 days to file their CCO annual reports. Such firms and their CCOs are also exempt from the requirement to file the CCO annual report simultaneously with the Form 1-FR-FCM or FOCUS Report, as applicable. The relief is only valid during calendar year 2014. CFTC Letter No. 13-84 is available here.
In No-Action Letter No. 13-85, the DSIO provides relief to certain SDs and their CCOs from the requirement to file a CCO annual report for the fiscal year ending December 31, 2013. To qualify for such relief, an SD must (i) not have been required to register as an SD prior to December 31, 2013, and (ii) have a fiscal year-end of December 31, 2013. CFTC Letter No. 13-85 is available here.