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  1. #1

    CFTC’s swap dealer rule for compliance chiefs: many questions in first “annual reports”

    NEW YORK, Oct. 1, 2014 (Thomson Reuters Accelus) – New rules governing swap dealers and the requirements for dedicated chief compliance officers are now more than a year in effect, and a new review of the so-called “annual reports” that dealers must submit to the Commodities Futures Trading Commission suggest there are still lingering questions over the roles and responsibilities of CCOs, particularly for non-U.S. dealers.

  2. #2

    CFTC’s swap dealer rule for compliance chiefs: many questions in first “annual reports”

    The review, published by the law firm Wilmer Hale , found that as of May 31, 2014, 105 entities were provisionally registered as swap dealers, and therefore subject to the CFTC’s CCO rule, which came into force in December 2012. The study noted that of the total population, 53 were located in the United States, with the rest in other jurisdictions, including the European Union, Canada, Australia, Hong Kong, Japan, Mexico, Singapore, and Switzerland.

  3. #3

    CFTC’s swap dealer rule for compliance chiefs: many questions in first “annual reports”

    The annual report that dealers must provide the commission cover a wide range of compliance issues. They include evidence of trading that would raise conflicts of interest and events that are deemed as non-compliant with rules governing swap trading. The CCO must in effect attest to the CFTC that the firm is compliant through written communication – the “annual report.”

  4. #4

    CFTC’s swap dealer rule for compliance chiefs: many questions in first “annual reports”

    “The comparability determinations permit non-U.S. swap dealers to comply with most of the CCO requirements of their home jurisdictions — including the annual reporting requirements of their home jurisdictions — rather than the requirements under the CCO Rule (i.e., “substituted compliance”),” the review said.

  5. #5
    content from reference site

  6. #6

    CFTC’s swap dealer rule for compliance chiefs: many questions in first “annual reports”

    In essence, both U.S. and non-U.S. swap dealers require that CCOs be “actively engaged in all aspects of swap dealer compliance, be provided with both the authority and resources to facilitate effective compliance, and have direct and meaningful access to the swap dealer’s governing body.”

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