On 23 July 2014, the US Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter that provides additional time for reporting parties to comply with certain reporting requirements under the ownership and control final rule (“OCR Final Rule”). The OCR Final Rule, which was adopted on 18 November 2014, requires reporting parties to submit electronically trader identification and market participation data.

In the no-action letter, the CFTC provides time-limited no-action relief from the new electronic reporting requirements of the OCR Final Rule, subject to certain terms and conditions outlined in the no-action letter, including the requirement that reporting parties must continue to report via non-automated submission methods during the period of the relief.

The full text of the CFTC no-action letter is available at:

http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/14- 95.pdf