CFTC Proposes Relief From Trade Option Reporting And Recordkeeping Requirements For Commercial End Users

On April 30, 2015, the Commodity Futures Trading Commission ("CFTC") approved for publication in the Federal Register proposed amendments to the trade option exemption (the "Proposal") that would reduce reporting and recordkeeping requirements for trade option counterparties that are not swap dealers or major swap participants ("Non-SD/MSPs"). Notably, the Proposal would eliminate the annual Form TO filing requirement for Non-SD/MSPs in connection with their trade options, while requiring them to notify the CFTC's Division of Market Oversight ("DMO") if their trade options have, or are expected to have, an aggregate notional value in excess of $1 billion in any calendar year. The Proposal will be available for public comment for 30 days after its forthcoming publication in the Federal Register. The Proposal is available here.