On November 10 2016 the Commodity Futures Trading Commission (CFTC) announced its unanimous approval of a final rule amending CFTC Regulation 3.3 to provide for a 90-day window after the end of an institution's fiscal year for the filing of chief compliance officer annual reports.(1)

The amendment applies to futures commission merchants, swap dealers and major swap participants. The amendment also clarifies the filing requirements for swap dealers and major swap participants in jurisdictions for which the CFTC has granted a comparability determination on the reports' contents. The rule will be effective upon publication in the Federal Register.

For further information on this topic please contact Donna M Parisi, Geoffrey B Goldman or Azam H Aziz at Shearman & Sterling LLP by telephone (+1 212 848 4000) or email ([email protected], [email protected] or [email protected]). The Shearman & Sterling website can be accessed at www.shearman.com.


(1) The final rule is available at www.cftc.gov/idc/groups/public/@lrfederalregister/documents/file/2016-27525a.pdf.