WASHINGTON, D.C. — The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) today issued a no-action letter that extends the current no-action position for reporting obligations under the ownership and control reports final rule (OCR Final Rule). The OCR Final Rule, approved in 2013, requires the electronic submission of trader identification and market participant data for special accounts and volume threshold accounts through Form 102 and Form 40.

DMO is extending its no-action position to address continuing compliance difficulties associated with certain OCR reporting obligations identified by reporting parties and market participants. The position announced today extends DMO’s previously provided position under CFTC Letter No. 23-14, stating that DMO will not recommend the CFTC commence an enforcement action for non-compliance with certain obligations. These obligations include, among others, the timing of OCR form filings; certain information required to be reported regarding trading account controllers and volume threshold account controllers on Form 102; the reporting threshold that triggers the reporting of a volume threshold account on Form 102; the filing of refresh updates for Form 102; and responses to certain questions on Form 40.  

The no-action position will remain in effect until the later of the applicable effective date or compliance date of a Commission action, such as a rulemaking or order, addressing such obligations.

Detailed information on the mechanics of reporting required by the OCR Final Rule and other relevant OCR Final Rule implementation information is provided on the OCR homepage.