FIA’s Law & Compliance Audit Trail Working Group made a presentation to the U.S. Commodity Futures Trading Commission's Technology Advisory Committee (TAC) on Feb. 26. The presentation focused on the following primary audit trail recommendations, with a goal of eliminating redundancies:
- Amend CFTC regulations to eliminate the requirement that Designated Contract Markets (DCMs) conduct annual audit trail reviews and to remove the specific elements of an adequate transaction database;
- Confirm that DCMs may maintain records of Tier 1 Data on behalf of Futures Commission Merchants (FCMs) and other trading participants; and
- DCMs should amend their rules to confirm that clearing FCMs do not have to maintain records of orders that are transmitted directly into the DCM trading system by direct access customers.
Presenters at the TAC meeting included:
- Natalie Tynan, Associate General Counsel, Head of Technology Documentation Strategy, FIA
- Tammy Botsford, Executive Director and Assistant General Counsel, J.P. Morgan
- Mark Fabian, Vice President, Market Regulation, ICE Futures U.S.
- Jeff Ramsey, Managing Director and General Counsel, Geneva Trading
- Andrew Vrabel, Executive Director, Global Head of Investigations, CME Group
Download the working group's presentation
Contact Natalie Tynan
