Client Alert

CFTC Amends Chief Compliance Officer Duties and Annual Report Requirements

05 Sep 2018

On August 27, 2018, the Commodity Futures Trading Commission (“CFTC”) published final rules in the Federal Register amending its regulations regarding duties of chief compliance officers (“CCOs”) of swap dealers (“SD”), major swap participants (“MSPs”) and futures commission merchants (“FCMs”) (collectively, “Registrants”) and requirements for preparing, certifying and furnishing to the CFTC the annual report containing an assessment of these Registrants’ compliance activities. The overarching goals of the rule amendments are to make clarifications regarding the rules in light of the CFTC’s experience in administering them and harmonize the CFTC’s rules with similar rules of the Securities and Exchange Commission (“SEC”) applicable to security-based swap dealers. 

Read our client alert.



Unsolicited e-mails and information sent to Morrison & Foerster will not be considered confidential, may be disclosed to others pursuant to our Privacy Policy, may not receive a response, and do not create an attorney-client relationship with Morrison & Foerster. If you are not already a client of Morrison & Foerster, do not include any confidential information in this message. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.