July 14, 2020
CFTC Amends Commercial End-User Trade Option Reporting Exemption | Practical Law
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About Miki Kolobara

Before entering into an agricultural trade option, the CFTC requires that an ATOM disclose to its customer information about the general risks of agricultural trade options. Disclosures can be printed or electronic. An ATOM must also provide its customers with: a written confirmation of each agricultural trade option contract;. 3/16/ · Accordingly, the CFTC’s press release states that “CFTC staff is of the view that a trade option counterparty that is a Non-SD/MSP is not required to report its otherwise unreported trade options for calendar year on Form TO.” Removal of Reporting Requirements. 9/23/ · However, prior to the TO Final Rule, trade options that met the trade option exemption were still subject to reporting requirements pursuant to part 45 of CFTC regulations if at least one of the non-SD/MSP counterparties had become obligated to comply with part 45 reporting requirements in the preceding month period in connection with a non-trade option swap trading activity.

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3/19/ · On March 16, , the Commodity Futures Trading Commission (the “CFTC”) adopted a final rule that eliminates reporting and recordkeeping requirements by “end-user” counterparties to trade option transactions. The final rule will become effective upon publication in the Federal Register. The immediate impact of the final rule is that end-users will not have to file. On March 16, , the CFTC approved a final rule that amends the reporting and recordkeeping exemption, known as the trade option exemption, for trade option counterparties that are not swap dealers (SDs) or major swap participants (MSPs). The effective date of . Under the Commission’s LTRS, clearing members, FCMs, and foreign brokers (collectively called reporting firms) file daily reports with the Commission under Part 17 of the CFTC’s regulations. The reports show futures and option positions of traders with positions at or above specific reporting levels as set by the Commission.

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On March 16, , the CFTC approved a final rule that amends the reporting and recordkeeping exemption, known as the trade option exemption, for trade option counterparties that are not swap dealers (SDs) or major swap participants (MSPs). The effective date of . Under the Commission’s LTRS, clearing members, FCMs, and foreign brokers (collectively called reporting firms) file daily reports with the Commission under Part 17 of the CFTC’s regulations. The reports show futures and option positions of traders with positions at or above specific reporting levels as set by the Commission. 3/16/ · Accordingly, the CFTC’s press release states that “CFTC staff is of the view that a trade option counterparty that is a Non-SD/MSP is not required to report its otherwise unreported trade options for calendar year on Form TO.” Removal of Reporting Requirements.

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CFTC Eliminates Certain Trade Option Reporting and Recordkeeping Requirements for End Users

Before entering into an agricultural trade option, the CFTC requires that an ATOM disclose to its customer information about the general risks of agricultural trade options. Disclosures can be printed or electronic. An ATOM must also provide its customers with: a written confirmation of each agricultural trade option contract;. 5/12/ · Nevertheless, the CFTC viewed Form TO as an accommodation to end-users that objected to applying the Part 45 swap reporting rules to trade options. After all, Form TO requires only the aggregate notional values of trade options exercised in a given calendar year (if any) to be reported, whereas Part 45 would require the reporting of significant detail regarding the date, time, parties, etc. . Under the Commission’s LTRS, clearing members, FCMs, and foreign brokers (collectively called reporting firms) file daily reports with the Commission under Part 17 of the CFTC’s regulations. The reports show futures and option positions of traders with positions at or above specific reporting levels as set by the Commission.

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9/23/ · However, prior to the TO Final Rule, trade options that met the trade option exemption were still subject to reporting requirements pursuant to part 45 of CFTC regulations if at least one of the non-SD/MSP counterparties had become obligated to comply with part 45 reporting requirements in the preceding month period in connection with a non-trade option swap trading activity. 3/28/ · The Commodity Futures Trading Commission (CFTC or Commission) adopted a final rule effective March 21, , 1 that eliminates the reporting and recordkeeping requirements under the CFTC’s existing trade option exemption for counterparties that are neither swap dealers (SDs) nor major swap participants (MSPs) (these non-SD/MSP counterparties are referred to herein as . Under the Commission’s LTRS, clearing members, FCMs, and foreign brokers (collectively called reporting firms) file daily reports with the Commission under Part 17 of the CFTC’s regulations. The reports show futures and option positions of traders with positions at or above specific reporting levels as set by the Commission.