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ARTICLE · 10 MARCH 2020

FIA Urges CFTC To Amend Audit Trail Requirements

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The FIA Law & Compliance Audit Trail Working Group urged the CFTC to amend certain audit trail requirements.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The FIA Law & Compliance Audit Trail Working Group urged the CFTC to amend certain audit trail requirements. In general, the recommendations are intended to eliminate "non‐value‐adding work," and reduce the retention of multiple redundant copies of audit trail records.

At a CFTC Technology Advisory Committee meeting, the FIA Audit Trail Working Group recommended modifying:

  • CFTC Rule 38.553 ("Enforcement of audit trail requirements") by no longer mandating that Designated Contract Markets ("DCMs") conduct annual audit trail reviews; and
  • CFTC Rule 38.552 ("Elements of an acceptable audit trail program") by eliminating elements of what constitutes an "adequate transaction database."

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