On March 27, 2015, the CFTC issued No-action Letter 15-15 (No-action 15-15) granting an additional 30 days for futures commission merchants (FCMs), swap dealers (SDs) and major swap participants (MSPs) (collectively, registrants) to submit their annual Dodd-Frank chief compliance officer (CCO) reports under CFTC Regulation 3.3(f). Under Regulation 3.3(f) (17 C.F.R. 3.3(f)), annual Dodd-Frank CCO reports must be furnished to the CFTC within 60 days after the end of the registrant's fiscal year. No-action 15-15 extends this deadline and provides that annual Dodd-Frank CCO reports must be furnished to the CFTC within 90 days after the end of the registrant's fiscal year.

This relief will remain in effect until the adoption of a rule or rule amendment that modifies the timing requirements of CFTC Regulation 3.3(f)(2), though the CFTC retains the authority to condition further, modify, suspend, terminate or otherwise restrict the terms of the no-action relief provided, in its discretion. The relief was granted in response to a March 10, 2015 request from the Futures Industry Association (FIA) and ISDA.

The annual CCO compliance report must cover the registrant's Dodd-Frank compliance programs for the registrant's most recently completed fiscal year and must be provided to the firm's board of directors or senior officer, as well as to the CFTC. For further information on the requirements of Regulation 3.3, see Legal Update, CFTC Issues Relief on 2014 Dodd-Frank CCO Reports.

The relief will allow additional time for FCMs, SDs and MSPs to: