The Division of Market Oversight of the Commodity Futures Trading Commission has extended no-action relief from certain of the CFTC’s ownership and control reporting (OCR) regulations, including electronic reporting via new Form 71, revised Form 40/40S and revised Form 102 (which includes Form 102A, Form 102B and Form 102S). CFTC Letter No. 15-03 replaces CFTC Letter No. 14-95, which previously granted similar relief. 

Specifically, CFTC Letter No. 15-03 provides temporary relief from the reporting requirements of (1) Form 102A and Form 102S until September 30, 2015, (2) Form 102B with respect to designated contract market volume threshold accounts until September 30, 2015, (3) Form 102B with respect to swap execution facility volume threshold accounts until February 13, 2017, and (4) Form 40/40S and Form 71 until February 11, 2016. To rely on this relief, market participants must continue to submit legacy Form 102, Form 102S and Form 40/40S, as applicable. Market participants must additionally cooperate with staff of the CFTC’s Office of Data and Technology to test and implement any information technology standards or systems related to OCR.

CFTC Letter No. 15-03 also includes specific instructions on submitting legacy Form 102, Form 102S and Form 40/40S.

The letter is available here.