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.