OCC Comment on CFTC RIN 3038-AF27 Large Trader Reporting Requirements

Megan M. Cohen
August 28, 2023
By Megan M. Cohen ,General Counsel and Corporate Secretary

The Options Clearing Corporation (“OCC") appreciates the opportunity to submit these comments on the above-referenced proposal (“Proposal” or “Proposed Rules”) under the Commodity Exchange Act (“Exchange Act”). The Commodity Futures Trading Commission (“CFTC” or “Commission”) is proposing to modernize its large trader reporting (“LTR”) requirements under CFTC Rule 17.00 by (i) updating the submission standard for certain reports; and (ii) replacing certain enumerated data fields with an appendix specifying applicable data elements and a separate Guidebook specifying the form and manner for reporting.

OCC currently collects large trader reporting information from 132 entities and submits that information to the CFTC on behalf of a designated contract market (“DCM”). OCC therefore has a keen interest in both in supporting the Commission’s goal of modernizing the reporting requirements, as well as ensuring that any changes to the LTR requirements are implemented in a manner designed to facilitate a smooth transition within a realistic timeframe, without excessive burdens on impacted entities. As discussed below, while we appreciate the Commission’s attention to modernizing the LTR requirements, we encourage the Commission to consider and address the significant technical ambiguities in the Proposed Rules and Guidebook, as well as the potential costs and burdens of implementing the proposed changes. Further, we request that the Commission provide at least a 2-year transition period to the new LTR requirements in light of the extensive technology changes and testing work with reporting entities needed for such a significant project.

Read more

Your acceptance of all cookies will permit robust site functionality. If you don't allow cookies, some features and functionality of OCC's site may not operate as expected. If you do not choose either cookie setting for our site, or if you close this window, this message will continue to display on each page you visit. Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies. For more details on cookies this site uses, see our OCC Site Cookies page. In addition to using cookies, we retain other information, including your Internet Protocol (IP) address, for the purposes listed in the Privacy Policy. Do not accept analytic cookies Accept analytic cookies