The Commodities and Derivatives Group in the Washington, DC, office of Norton Rose Fulbright has published a User’s Guide to a CFTC staff advisory and time-limited no-action letter regarding the annual report required of chief compliance officers (CCOs) of futures commission merchants, swap dealers, and major swap participants.

The User’s Guide walks through the specific recommendations in the staff advisory for preparing CCO annual reports.  The staff advisory provides useful insights into staff’s expectations for the content and level of granularity necessary for the CCO annual report, and includes an example of how a chart can be used to address a number of the requirements of such a report.

This staff guidance is particularly important given that each annual report must include a certification “under penalty of law” by the CCO or CEO of the firm that, to the best of his or her knowledge and reasonable belief, the information contained in the annual report is accurate and complete.

Relevant links:
CFTC Staff Advisory–CCO Annual Reports
CFTC Staff No-Action Letter–CCO Annual Reports