NFA Supports CFTC Rule Changes On CCO Duties And Obligations

The National Futures Association ("NFA") submitted a comment letter in support of proposed CFTC amendments (see  previous coverage) regarding the duties of Chief Compliance Officers ("CCOs") and narrowing CCO Annual Reporting requirements.

Specifically, the NFA expressed support for changes to (i) CFTC Regulation 3.3(e)(2), which would remove the requirement that futures commission merchants ("FCMs") and swap dealers ("SDs") review all applicable Commodity Exchange Act requirements and identify relevant policies and procedures designed to ensure compliance to the relevant requirement, (ii) Regulation 3.3(d)(1) to establish that the duties of CCOs are specific to activities related to the duties of a firm as an FCM or SD, and (iii) CFTC Regulation 3.3(e)(4), narrowing the CCO Annual Report requirement so that CCOs need to discuss compliance resources only for the FCM or SD rather than for all of the business activities of the firm.