Jonas Robison

Senior Associate

New York

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Jonas Robison, a Senior Associate in Orrick’s New York office, is a member of the Structured Finance Group. He has a broad financial regulatory practice, including frequently advising on derivatives regulations and CFTC matters. His practice also focuses on securitization and negotiating derivatives transactions. 

He has experience with derivatives regulations under the Dodd-Frank Act, bank regulations, regulatory requirements applicable to virtual currencies and blockchain technology, and the securities laws generally. He also represents issuers and underwriters in commercial mortgage loan, auto loan, credit card, and other types of securitizations. In addition, he has broad experience in general corporate matters.

Posts by: Jonas Robison

CFTC Issues Advisory Regarding Chief Compliance Officer Annual Report Requirements


On December 4, the CFTC issued an advisory (Staff Advisory 19-24) providing further guidance on certain requirements applicable to swap dealers, futures commission merchants and major swap participants (collectively, Registrants) in connection with the preparation and submission of chief compliance officer annual compliance reports (CCO Annual Reports) pursuant to CFTC Regulation 3.3. The CFTC had previously issued: (i) a final rule governing CCO Annual Reports in 2012; (ii) a related staff advisory in 2014; (iii) a final rule modifying certain regulations related to the CCO Annual Report requirements in December 2018; and (iv) guidance focused on certain of those requirements in December 2018.

After reviewing CCO Annual Reports submitted for the 2018 fiscal year, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the CFTC issued Staff Advisory 19-24 to provide additional guidance to Registrants regarding the CCO Annual Report requirements. Staff Advisory 19-24 addresses the following areas of the CCO Annual Report: (i) areas for improvement; (ii) financial, managerial, operational, and staffing resources; (iii) material non-compliance issues; (iv) furnishing the annual report and related matters; (v) the certification requirement; (vi) compliance with the Volcker Rule; and (vii) other miscellaneous items. The Advisory also notes that, if a Registrant files a CCO Annual Report that DSIO staff determines is noncompliant, the Registrant may be required to file a corrected CCO Annual Report pursuant to CFTC Regulation 3.3(f)(4). Release.