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ARTICLE · 03 OCTOBER 2017

CFTC Extends No-Action Relief From OCR Reporting Obligations

Hogan Lovells Cadwalader
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The CFTC Division of Market Oversight ("DMO") extended existing no-action relief (see previous coverage)...

United StatesFinance and Banking

The CFTC Division of Market Oversight ("DMO") extended existing no-action relief (see previous coverage) and granted additional relief to reporting entities from ownership and control reporting ("OCR") requirements. Specifically, the relief was granted from OCR requirements for CFTC Forms 102/102S, 40/40S and 71.

The relief was granted in response to requests from the Futures Industry Association and the Commodity Markets Council. The OCR final rule instituted requirements intended to enhance the identification of futures and swap market participants, and included several reporting requirements to collect ownership and control information for active accounts. The DMO previously granted certain no-action relief to address concerns that the OCR requirements presented compliance issues that made it difficult for entities to "fully comply" with certain aspects of the rule.

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