The Commission adopted revisions to its Ownership and Control Reports (OCR) regime in 2013.[1]  The updated forms were supposed to provide the Commission with greater insight into who owns and who controls futures and swaps accounts.  They were also supposed to provide the Commission with information, for the first time, about market participants who trade large volumes in the futures and swaps markets, but end the day without reportable positions.  Unfortunately, the 2013 revisions have proven to be unworkable for reporting entities.  For example, reporting entities have found impractical the low 50-contract reporting threshold and the requirement to report to the Commission the names of trading account owners by 9 a.m. ET on the business day following the day on which the account becomes reportable.  This is why some of the requirements have been the subject of successive no-action letters since the 2013 amendments.  I support today’s extension of no-action relief that provides critical relief from the most burdensome and confusing requirements of the OCR forms.

I hope the Commission will prioritize revisiting this rule in the near future and fix, once and for all, the outstanding issues that have been lingering since the rule was last revised.  I believe there is a way to simplify these forms, while still providing the Commission with mission-critical data.  The Division of Market Oversight (DMO) has done a remarkable job of improving other incredibly complicated and technical reporting regimes, including the recent amendments to parts 43, 45, and 49 swap reporting regulations.  DMO is also currently finalizing many other complex, significant rulemakings, including position limits and risk principles for electronic trading.  I commend DMO staff for their tireless work on these pressing priorities and hope that as these milestones are accomplished, they can turn their efforts to developing a permanent solution to the Commission’s OCR requirements.