FIA comments on CFTC 1.31 recordkeeping requirements

20 March 2017

FIA submitted comments to the CFTC in support of proposed amendments to recordkeeping requirements set out in Commission Rules 1.31. The amendments move the rule from prescriptive requirements mandating the use of outdated technology to more technology-neutral and principles-based policy.  

FIA's comments request additional clarification of certain aspects of the proposed amendments and suggest certain further revisions to the proposed amendments that are consistent with their underlying purpose .  

The full letter is available here.

  • FIA