OCR Final Rule

No-Action Relief Regarding Masking Information Reportable under the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the masking of information reportable under the ownership and control final rule (the “OCR Final Rule”).  The no-action letter permits reporting parties with reporting obligations on OCR Forms 102A and 102B to mask certain identifying information, subject to conditions, until the earlier of: (i) a reporting party no longer holding the requisite reasonable belief regarding the privacy law consequences of reporting; and (ii) March 1, 2017. Release.

No-Action Letter Issued Regarding the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the ownership and control final rule (the “OCR Final Rule”).  The OCR Final Rule requires the electronic submission of trader identification and market participant data on new and updated forms.  The no-action letter extends certain relief previously provided and is intended to provide improvements in the reliability and consistency of the OCR data submitted to the CFTC. Release.

CFTC Issues Advisory on Reporting Obligations Pursuant to the Ownership and Control Final Rule

On March 23, CFTC Division of Market Oversight and Division of Swap Dealer and Intermediary Oversight issued a staff advisory to remind certain reporting parties (including futures commission merchants, clearing members, foreign brokers, swap dealers and certain reporting markets) of their obligation to obtain information on a timely basis from their customers or counterparties in order to comply with the ownership and control reports final rule (OCR Final Rule).  ReleaseStaff AdvisoryOCR Final Rule.