On May 3, 2017, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to its rules regarding the duties of Chief Compliance Officers (“CCOs”) for swap dealers (“SDs”), major swap participants (“MSPs”), and futures commission merchants (“FCMs”) (collectively, “Registrants”) and content and submission requirements for annual reports (“Proposal”). The overarching goals of the Proposal are to make certain clarifications regarding the rules based on CFTC experience and input from CCOs, to harmonize the CFTC’s rules with similar rules of the Securities and Exchange Commission (“SEC”) applicable to security-based swap dealers, and to reduce regulatory burden for Registrants. The comment period for the proposed rules closes on July 7, 2017.

The Proposal would make the following modifications to CFTC Regs. 3.1 and 3.3...