In letters submitted to the Commodity Futures Trading Commission, industry organizations were generally supportive of the Commission’s recently proposed changes to the enumerated duties of chief compliance officers of futures commission merchants and swap dealers. Among other things, the CFTC’s amendments, if adopted, would eliminate the current requirement that annual reports identify each specific law provision and CFTC rule that pertains to an FCM and SD and specifically tie each such provision to the precise firm policies and procedures that are reasonably designed to ensure compliance. In a joint response letter, the Futures Industry Association and the Securities Industry and Financial Markets Association commended the CFTC for seeking to promote consistency with parallel requirements adopted by other regulators while reducing regulatory burdens and enhancing regulatory oversight. However, the industry organizations identified other measures the Commission should take to enhance alignment of its CCO rules with those of the Securities and Exchange Commission and the Financial Industry Regulatory Authority. Among other things, the two groups urged the Commission to define what specific responsibilities a CCO must fulfill to “administer” a registrant’s compliance policies and procedures as required under the proposed amended Commission rule. Likewise, the National Futures Association urged the Commission to more clearly define the CCO’s role to be that of an independent advisor and not a supervisor. Contrariwise, Better Markets argued that the CFTC’s proposed amended rule “strays from the CFTC’s overarching duty to put public interest above concerns about regulatory costs and burdens, efficiencies, and regulatory harmony.” (Click here for background on the CFTC’s CCO proposal in the article “CFTC Recommends Amendments to CCO Obligations and Annual Reports” in the May 7, 2017 edition of Bridging the Week.