On August 9, the Commodity Futures Trading Commission announced that it is proposing amendments to CFTC Regulation 3.3 to codify and supersede no-action relief previously granted in CFTC Staff Letter No. 15-15, issued March 27, 2015, with respect to the date by which the Chief Compliance Officer (CCO) of each futures commission merchant, swap dealer (SD) and major swap participant (MSP) (each a registrant) must file an annual report (CCO Annual Report) with the CFTC. Regulation 3.3 currently provides that the CCO Annual Report must be filed with the CFTC not more than 60 days after the registrant’s fiscal year-end. Consistent with Letter No. 15-15, the amendments, if adopted, would provide each registrant an additional 30 days to file the CCO Annual Report.

The amendments also seek to address the timing of the filing requirement for comparable annual reports (Comparable Annual Reports). Namely, if the compliance requirements of SDs and MSPs located in certain jurisdictions (Canada, the European Union, Hong Kong, Japan or Switzerland) identify a specific date by which Comparable Annual Reports must be completed, then the CFTC is proposing that Comparable Annual Reports may be furnished to the CFTC electronically up to 15 days after the date on which the Comparable Annual Report must be completed in the relevant jurisdiction.

The CFTC is seeking comments on the proposed amendments. The comment period ends 30 days after the proposal’s publication in the Federal Register.

For more information about the proposal click here.