FIA, along with the International Swaps and Derivatives Association (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) submitted a letter to the CFTC on the process for filing the Chief Compliance Officer (CCO) Annual Report for Futures Commission Merchants, Swap Dealers and Major Swap Participants.
The comments reflect concerns regarding linking the filing date of the CCO Annual Report to the submission of the registrants’ annual financial reports. Linking the filing date of the CCO annual report to an organization's annual financial report ignores the inherent differences, in terms of both substance and process, between CCO annual reports and annual financial reports. These reports are typically prepared by different groups within an organization, contain different information, and are used for different purposes. FIA, ISDA and SIFMA recommend that the time period for filing the CCO annual report be 30 days following the deadline for filing financial reports, as opposed to the actual submission date.
Additionally, FIA, ISDA and SIFMA asked the Commission to clarify the start of the 15-day period for filing a comparable annual report for organizations that are subject to a substituted compliance determination with the CFTC. Because comparable annual reports have different deadlines in different countries, which are not necessarily static, FIA, ISDA and SIFMA recommended that the deadline begin "as provided under relevant law or regulation in the home jurisdiction of the Substituted Compliance Registrant, or as otherwise set by the home regulator of the Substituted Compliance Registrant.”
The full letter is available here in Resources on the right.