The CFTC Unanimously Approves for Public Comment Rules to Ease Trade Option Obligations for End Users



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The U.S. Commodity Futures Trading Commission (CFTC) issued proposed rules to amend Part 32 to reduce recordkeeping and reporting requirements for commercial end users entering into trade options. The proposed rules, if finalized in the form proposed, would eliminate the annual Form TO filing requirement and the Part 45 swap reporting requirements. The end user would need to obtain a legal entity identifier (LEI) as required by Rule 45.6, but would not be required to use unique swap identifiers (USIs) or unique product identifiers (UPIs). End users would be required to notify the CFTC within 30 days if their trade options (whether reported or unreported) exceed (or are expected to exceed) $1 billion in aggregate nominal value in any calendar year. You can read the Notice of Proposed Rulemaking on the CFTC website. The public comment period remains open until June 6, 2015.