The CFTC issued a staff advisory reminding reporting parties of their obligation to obtain information on a timely basis from their customers or counterparties in order to comply with the final large-trader ownership and control (OCR) reporting rules.
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.
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 designated contract market (DCM) volume threshold accounts via New Form 102B until September 30, 2015.
Relief from electronically reporting swap execution facility (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.
Staff Advisory 15-14 advises reporting parties subject to the requirements to take steps to ensure that their customers and counterparties:
Respond promptly to requests from reporting parties for OCR information.
Promptly notify reporting parties of any subsequent updates to OCR information.
Otherwise assist reporting parties in fulfilling their reporting obligations under the final OCR rules.
Staff Advisory 15-14 further reminds reporting parties that they are subject to examination regarding their obligations under the final OCR rules by either:
The National Futures Exchange and/or the Chicago Mercantile Change (in their capacity as reporting parties' designated self-regulatory organizations (DSROs)).