September 21, 2021

Volume XI, Number 264

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September 20, 2021

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CFTC Provides Relief to DCOs from New Daily Reporting Requirements

The Division of Clearing and Risk (DCR) of the Commodity Futures Trading Commission (CFTC) has issued no-action relief to derivatives clearing organizations (DCOs) from the CFTC’s recently adopted daily reporting requirements.

As background, the CFTC amended CFTC Rule 39.19 to require DCOs, among other things, to report daily initial margin, variation margin, cash flow, and position information on an individual customer account basis. The compliance date for these amended reporting requirements would have been January 27. However, DCR has provided no-action relief from the amended reporting requirements until January 27, 2022 to permit additional time for the CFTC and DCOs to address operational and technological issues.

The press release and access to Staff Letter 21-01 are available here.

©2021 Katten Muchin Rosenman LLPNational Law Review, Volume XI, Number 8
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About this Author

Kevin M. Foley, Finance Lawyer, Katten Llaw Firm
Partner

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.

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312-902-5372
James M. Brady, Katten Muchin Law Firm, Finance Attorney
Associate

James Brady concentrates his practice in financial services matters.

While in law school, James was an editor of the Michigan Journal of International Law. He also served as a judicial intern to the Honorable Stephen J. Markman of the Michigan Supreme Court. http://www.kattenlaw.com/James-Brady

312-902-5362
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