Annual report season is here for chief compliance officers of futures commission merchants, swap dealers and security-based swap dealers with calendar fiscal years. This year's submission may be the most critical to a registrant's program yet.
Although many CFTC-registered futures commission merchants and swap dealers have filed the CCO annual report since 2013, recent settlement actions and an advisory by the U.S. Commodity Futures Trading Commission's Division of Enforcement, coupled with statements made by both CFTC and U.S. Securities and Exchange Commission leadership, all detailed later in this article, reflect close scrutiny of CCO annual reports, demonstrate why this year's filing is no ordinary exercise, and highlight the increasing importance of the CCO annual report and its usage.
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Read “Tips For CCOs Submitting Annual Compliance Reports,” co-authored by Ryan Hayden and published by Law360. (subscription)