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ARTICLE · 10 JANUARY 2016

CFTC Rule Change Brings Record-Keeping Relief For Commodity Dealers And End-Users

Thompson Coburn LLP
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Aiming to reduce needless regulatory costs on America's farmers, grain elevators and other commercial end-users of the commodity markets, the CFTC recently amended a record-keeping rule that had caused major headaches...

United StatesFinance and Banking
Richard Reibman
Richard Reibman
Gregory Mennerick
Gregory Mennerick
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Aiming to reduce needless regulatory costs on America's farmers, grain elevators and other commercial end-users of the commodity markets, the U.S. Commodity Futures Trading Commission (CFTC) recently amended a record-keeping rule that had caused major headaches for unregistered members.

The December 2015 change to CFTC Regulation 1.35(a) was aimed at solving problems in the previous version of the measure, which was characterized by a CFTC Commissioner as "unworkable" and levied compliance costs described by market participants as "prohibitively expensive."

Record-keeping: What's different?

The amended regulation is beneficial for hedgers and other commercial end-users of the commodity markets who are not registered in any capacity with the CFTC but who nonetheless hold membership or trading privileges on an exchange (for example, through a designated contract market or a swap execution facility).

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