The Division of Market Oversight of the Commodity Futures Trading Commission delayed for the third time the roll-out of new large trader reporting requirements that initially were adopted during November 2013 — the so-called “OCR Final Rule.” Under the OCR Final Rule, the CFTC expanded upon its prior large trader reporting regime and required the electronic submission of certain large traders’ and position holders’ data on updated forms:

  • new Form 102A to identify holders of large positions;
  • new Form 102B to identify traders that exceed a stated volume of transactions (50 contracts/day on a notional value basis; “volume threshold accounts”) during a single trading day (regardless of end-of-day positions);
  • new Form 102S to identify holders of certain swaps positions;
  • new Form 40/40S to collect information from reporting traders; and
  • new Form 71 to collect information on omnibus volume threshold accounts.

Under the CFTC’s new schedule, new requirements related to the electronic reporting of:

  • Forms 102A, 102B (for Designated Contract Market volume trading threshold accounts) and 102S go into effect on April 28, 2016;
  • Forms 40, 40S and new Form 71 go into effect on September 29, 2016; and
  • Form 102B (for Swap Execution Facility volume threshold trading accounts) go into effect on February 14, 2017.

In the interim period, recordkeeping requirements that became effective on August 14, 2014, and legacy non-automated reporting requirements are in effect. Designated contract markets have conformed their LTR requirements to the CFTC new deadlines.