On February 10 2015 the Commodity Futures Trading Commission (CFTC) issued a no-action letter (CFTC Letter 15- 03), which provides additional time for reporting parties to comply with certain reporting requirements of the ownership and control final rule. CFTC Letter 15-03 extends certain relief provided under CFTC Letter 14-95 – a no-action letter issued on July 23 2014 that extended time-limited no-action relief from certain reporting obligations under the final rule.

The final rule requires the electronic submission of trader identification and market participant data reporting forms. CFTC Letter 15-03 provides time-limited no-action relief for reporting parties from the requirement to file the forms electronically and provide certain additional information required by the final rule. The relief is extended to dates ranging from September 30 2015 to February 13 2017.

CFTC Letter 15-03 is available at www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/15-03.pdf.

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 (dparisi@shearman.com, geoffrey.goldman@shearman.com or aaziz@shearman.com). The Shearman & Sterling website can be accessed at www.shearman.com.

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