January 24, 2021

Volume XI, Number 24


January 22, 2021

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CFTC Extends No-Action Relief for Certain Reporting Obligations under the OCR Final Rule & Holding Open Commission Meeting on October 6

CFTC Extends No-Action Relief for Certain Reporting Obligations under the OCR Final Rule

On September 25, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) extended relief from certain reporting obligations under the ownership and control reports final rule (OCR Final Rule). The OCR Final Rule requires the electronic submission of trader identification and market participant data.  The current no-action letter, CFTC Letter No. 20-30, extends the relief, which was most recently granted in CFTC Letter No. 17-45, until September 29, 2023 (unless otherwise addressed by the CFTC).

Additional information is available here.

CFTC Letter No. 20-30 is available for download here.

CFTC to Hold Open Commission Meeting on October 6

On September 29, the Commodity Futures Trading Commission (CFTC) announced that it will hold an open meeting on Tuesday, October 6 at 10:30 a.m. (ET). The meeting will consider amendments to compliance requirements for Commodity Pool Operators on Form CPO-PQR and the memorandum of understanding between the CFTC and the Officer of Financial Research Regarding the Sharing of Data and Information Collected on Form CPO-PQR.

The meeting can be publicly accessed via live stream at www.cftc.gov on the CFTC’s YouTube channel or by phone (domestically at +1.877.951.7311; passcode: 3774262).

Additional information is available here.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume X, Number 276



About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm

Kevin M. Foley has extensive experience in commodities law and advises a wide range of clients, both in the United States and abroad, on compliance with the Commodity Exchange Act and the rules of the Commodity Futures Trading Commission (CFTC) affecting traditional exchange-traded products, as well as the over-the-counter markets involving swaps and other derivative instruments. His clients include futures commission merchants, derivatives clearing organizations, designated contract markets, foreign boards of trade and an industry trade association.



Timothy Kertland concentrates his practice on transactional, corporate and regulatory aspects of financial services matters. Timothy is able to provide legal services to a wide variety of clients including proprietary trading firms, hedge funds, broker-dealers, registered investment advisers, and commodity trading advisers.

While in law school, Timothy served as an editor of the Virginia Tax Review. As a first-year law student, he represented the University of Virginia School of Law at the National...