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ARTICLE · 13 NOVEMBER 2017

FCM Settles CFTC Charges Of Large Trader Reporting Violations

Hogan Lovells Cadwalader
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A futures commission merchant ("FCM") agreed to settle charges of reporting failures in connection with filing inadequate futures and options transaction data reports with the CFTC.

United StatesFinance and Banking

A futures commission merchant ("FCM") agreed to settle charges of reporting failures in connection with filing inadequate futures and options transaction data reports with the CFTC. Pursuant to CEA Section 4g(a) and CFTC Rule 17.00, FCMs are required to report certain futures and options transaction data through so-called "large trader reports."

In an Order, the CFTC alleged that Morgan Stanley, a registered FCM, relied on proprietary in-house software to generate these reports. The CFTC determined that deficiencies in Morgan Stanley's software led to the omission of required data for reports filed between 2007 and 2017. The omissions occurred as a result of problems with the software, which resulted in errors in the aggregation and reporting of the required data.

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