A Gentle Reminder: CFTC Issues No-Action Relief Letters to FCM Compliance Departments
- The US Commodity Futures Trading Commission has issued two no-action relief letters to FCMs detailing that they are not required to register as swap dealers with the CFTC, and that the fiscal year ends today.

Senior compliance officials within FX firms in North America will be able to relax and enjoy this evening's New Year's celebrations relatively unburdened with the administrative reporting often associated with the end of a financial year following the issuance by the Commodity Futures Trading Commission (CFTC CFTC The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss Read this Term) of two no-action letters that provide certain futures commission merchants, swap dealers, and major swap participants with limited relief surrounding the requirement that Chief Compliance Officers of such firms prepare and submit an Annual Report, pursuant to Commission Regulation Regulation Like any other industry with a high net worth, the financial services industry is tightly regulated to help curb illicit behavior and manipulation. Each asset class has its own set of protocols put in place to combat their respective forms of abuse.In the foreign exchange space, regulation is assumed by authorities in multiple jurisdictions, though ultimately lacking a binding international order. Who are the Industry’s Leading Regulators?Regulators such as the UK’s Financial Conduct Authority ( Like any other industry with a high net worth, the financial services industry is tightly regulated to help curb illicit behavior and manipulation. Each asset class has its own set of protocols put in place to combat their respective forms of abuse.In the foreign exchange space, regulation is assumed by authorities in multiple jurisdictions, though ultimately lacking a binding international order. Who are the Industry’s Leading Regulators?Regulators such as the UK’s Financial Conduct Authority ( Read this Term 3.3.
Swap Dealer Registration Deferred
The CFTC's Division of Swap Dealer and Intermediary Oversight (DSIO) declared in its first no-action letter relating to this matter that swap dealers have been provided with relief insofar as that they are not required, prior to December 31, 2013, to register with the CFTC as swap dealers, as well as reminding them that they have a fiscal year-end of December 31, 2013, representing today's date.
Within the same letter, the DSIO stated that it will not recommend that the CFTC take an enforcement action against any such firm, or a Chief Compliance officer of any such firm, for failing to prepare an Annual Report and furnish such Report to the CFTC for the fiscal year that ends on December 31, 2013.
In a separate letter, the DSIO provided relief to all futures commission merchants (FCMs), swap dealers, and major swap participants concerning the deadline for furnishing a copy of the Annual Report to the CFTC. The no-action relief provided in that letter is limited to the Annual Report required to be furnished by such firms during calendar year 2014.
Senior compliance officials within FX firms in North America will be able to relax and enjoy this evening's New Year's celebrations relatively unburdened with the administrative reporting often associated with the end of a financial year following the issuance by the Commodity Futures Trading Commission (CFTC CFTC The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss Read this Term) of two no-action letters that provide certain futures commission merchants, swap dealers, and major swap participants with limited relief surrounding the requirement that Chief Compliance Officers of such firms prepare and submit an Annual Report, pursuant to Commission Regulation Regulation Like any other industry with a high net worth, the financial services industry is tightly regulated to help curb illicit behavior and manipulation. Each asset class has its own set of protocols put in place to combat their respective forms of abuse.In the foreign exchange space, regulation is assumed by authorities in multiple jurisdictions, though ultimately lacking a binding international order. Who are the Industry’s Leading Regulators?Regulators such as the UK’s Financial Conduct Authority ( Like any other industry with a high net worth, the financial services industry is tightly regulated to help curb illicit behavior and manipulation. Each asset class has its own set of protocols put in place to combat their respective forms of abuse.In the foreign exchange space, regulation is assumed by authorities in multiple jurisdictions, though ultimately lacking a binding international order. Who are the Industry’s Leading Regulators?Regulators such as the UK’s Financial Conduct Authority ( Read this Term 3.3.
Swap Dealer Registration Deferred
The CFTC's Division of Swap Dealer and Intermediary Oversight (DSIO) declared in its first no-action letter relating to this matter that swap dealers have been provided with relief insofar as that they are not required, prior to December 31, 2013, to register with the CFTC as swap dealers, as well as reminding them that they have a fiscal year-end of December 31, 2013, representing today's date.
Within the same letter, the DSIO stated that it will not recommend that the CFTC take an enforcement action against any such firm, or a Chief Compliance officer of any such firm, for failing to prepare an Annual Report and furnish such Report to the CFTC for the fiscal year that ends on December 31, 2013.
In a separate letter, the DSIO provided relief to all futures commission merchants (FCMs), swap dealers, and major swap participants concerning the deadline for furnishing a copy of the Annual Report to the CFTC. The no-action relief provided in that letter is limited to the Annual Report required to be furnished by such firms during calendar year 2014.