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ARTICLE · 20 MAY 2024

Financial Markets And Funds Quick Take | Issue 26

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Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds.

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Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds.

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FIX(ML)ing the Data Submission Standard: The CFTC's Large Trader Rules Get a Makeover

By Stephen Morris, Nicholas Gervasi

Part 17 of the Commodity Futures Trading Commission's (CFTC) regulations require futures commission merchants (FCMs), clearing members of registered derivatives clearing organizations and foreign brokers holding omnibus accounts with such FCM clearing members to submit reports of the positions held by "large traders" (i.e., traders controlling positions exceeding thresholds prescribed under those regulations). For reporting firms, large trader reporting presents perhaps the most stubborn compliance challenge in the CFTC rulebook. Part 17's difficulties largely stem from conforming

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