Public Statements & Remarks

January 3, 2020

Statement of Division of Swap Dealer and Intermediary Oversight on Annual Compliance Report Requirements

On December 4, 2019, the Division of Swap Dealer and Intermediary Oversight (DSIO) issued an advisory regarding annual compliance report requirements for swap dealers, futures commission merchants, and major swap participants (Advisory).[1] The Advisory clarifies annual compliance reporting requirements for those categories of registered firms and provides additional recommendations to those firms regarding the manner in which they prepare their reports. DSIO intends the Advisory to help registrants improve the quality and usefulness of their reports in accordance with their existing obligations under CFTC Regulation 3.3.[2]

DSIO considers the Advisory to be targeted in scope and to reflect certain iterations in its thinking about how annual compliance reports can be more effective, based on its years of experience in reviewing reports submitted by registered firms. At the same time, DSIO is aware that having issued the Advisory in December may present challenges for chief compliance officers (CCOs) of registered firms to adapt their existing reporting procedures in time to produce reports in 2020 that take the Advisory into full consideration.  

The Advisory is merely guidance and does not impose any new requirements. As such, DSIO expects that CCOs will take reasonable measures to implement the Advisory’s recommendations when preparing their annual compliance reports for 2019. DSIO recognizes that CCOs may not be able to implement those recommendations fully for their 2019 reports given the potential timing constraints identified above. DSIO does expect, however, that CCOs will be able to consider those recommendations more completely when preparing their 2020 annual reports, which will be due in 2021.

Any questions regarding this statement should be directed to the following DSIO Staff members: Amanda Olear, Acting Deputy Director (202.418.5283, [email protected]); Pamela Geraghty, Special Counsel (202.418.5634, [email protected]); and Owen Kopon, Special Counsel (202.418.5360, [email protected]).

Joshua B. Sterling
Division of Swap Dealer and Intermediary Oversight


[1]; see also

[2] 17 C.F.R. § 3.3.