Co-authored by Maureen C. Guilfoile.
The National Futures Association (NFA) has reminded its members that new Chief Compliance Officer (CCO) requirements affecting all Futures Commission Merchants (FCMs) currently regulated by a US prudential regulator or in some capacity registered with the Securities and Exchange Commission take effect on October 1. In accordance with Commodity Futures Trading Commission Regulation 3.3, each affected FCM must designate a CCO and list that person as principal of the firm by October 1. An FCM must file a CFTC Form 8-R and a fingerprint card on behalf of the designated CCO unless the CCO is currently a principal. The FCM must also update the CCO Contact Information Section on the FCM’s CFTC Form 7-R. All forms must be completed through NFA’s Online Registration System.
Each affected FCM’s CCO must also file a CCO Annual Report as of the date of the FCM’s first fiscal year end after October 1, covering the period from October 1, 2012 through the date of the fiscal year end. The CCO Annual Report must be submitted electronically to the CFTC no later than 90 days following the fiscal year end.
More information is available here.