On September 30, 2013, the CFTC’s Division of Market Oversight (“DMO”) issued a Commodity Option FAQ document. While the document largely contains information already set forth in prior CFTC releases, it does contain helpful clarifications of potential interest to clients who enter into commodity options. These clarifications generally relate to the CFTC’s “Form TO,” the annual reporting form for trade options. They include what trade options must be reported, the reporting period for the first annual Form TO filing, the calculation of the notional amount of embedded options in forward contracts, and the applicability of the Form TO filing requirement to cross-border situations.

A summary of these clarifications is set forth below.