CFTC Extends Large-trader Ownership and Control (OCR) No-action Relief | Practical Law

CFTC Extends Large-trader Ownership and Control (OCR) No-action Relief | Practical Law

The CFTC granted additional time to comply with certain Dodd-Frank large-trader reporting requirements under the final OCR rules for members of the Futures Industry Association (FIA) that are obligated to report futures and swap transaction data to the CFTC under Parts 15, 17, 18 and 20 of the CFTC's regulations.

CFTC Extends Large-trader Ownership and Control (OCR) No-action Relief

Practical Law Legal Update 4-600-1586 (Approx. 3 pages)

CFTC Extends Large-trader Ownership and Control (OCR) No-action Relief

by Practical Law Finance
Published on 12 Feb 2015 • USA (National/Federal)
The CFTC granted additional time to comply with certain Dodd-Frank large-trader reporting requirements under the final OCR rules for members of the Futures Industry Association (FIA) that are obligated to report futures and swap transaction data to the CFTC under Parts 15, 17, 18 and 20 of the CFTC's regulations.
On February 10, 2015, the CFTC issued No-action Letter 15-03 (No-action 15-03), granting additional time to comply with certain reporting requirements under the final ownership and control (OCR) reporting rules for members of the Futures Industry Association (FIA) that are obligated to report futures and swap transaction data to the CFTC under Parts 15, 17, 18 and 20 of the CFTC's regulations. Compliance dates range from September 30, 2015 to February 13, 2017. (For more information on the final OCR rules, see Legal Update, CFTC Proposes Rules on Large-trader Ownership and Control Forms.)
Under the final OCR rules, reporting parties must electronically submit trader identification and market participant data on new and updated reporting forms (New Form 102A, New Form 102S, New Form 40/40S and New Form 71) to better identify participants in futures and swaps markets. No-action 15-03 replaces No-action 14-95 and extends relief granted in No-action 14-95 (see Legal Update, Dodd-Frank Swaps Roundup: Ownership and Control Data Reporting, Swap Dealer Rule Correction and More: Relief from Certain Ownership and Control (OCR) Swap Data Reporting Requirements) and grants:
  • Relief from electronically reporting via New Form 102A until September 30, 2015.
  • Relief from electronically reporting via New Form 102S until September 30, 2015.
  • Relief from electronically reporting DCM volume threshold accounts via New Form 102B until September 30, 2015.
  • Relief from electronically reporting SEF volume threshold accounts via New Form 102B until February 13, 2017.
  • Relief with respect to the obligation to report via New Form 40/408 and New Form 71 until February 11, 2016 (this relief is unchanged from No-action 14-95).
The relief is subject to certain terms and conditions, including the condition that reporting parties continue to report via the legacy, non-automated submission methods until the relief expires. Reporting parties are also expected to cooperate with staff of the CFTC's Office of Data and Technology (ODT) to provide test submissions in the form and manner requested by ODT.