CFTC Extends OCR Final Rule Relief

October 5, 2023

On September 22, 2023, the Commodity Futures Trading Commission’s (the “CFTC” or the “Commission") Division of Market Oversight extended its no-action position regarding certain large trader reporting (“LTR”) obligations for futures, options and swaps under parts 17, 18 and 20 of the CFTC's final rule on Ownership and Control Reports (see 78 Federal Register 69178; hereinafter, the “OCR Final Rule”). The no-action position granted in CFTC Letter No. 23-14 is an extension of relief from compliance with certain requirements under the OCR Final Rule that has been granted by the DMO since 2014, and will remain in effect until the earlier of a Commission action addressing the reporting obligations or September 30, 2024.  This relief applies to electronic submission of trader identification and market participant data on several forms: Form 40, Form 71 and Form 102 (including Forms 102A, 102B and 102S) (collectively, the “OCR Forms”).

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