The Commodity Futures Trading Commission (“CFTC”) has announced a proposed rule that could provide meaningful relief for those of our clients who engage in trade options (or suspected trade options) in the course of their business. The proposed rule would eliminate the requirement that entities that are not Swap Dealers or Major Swap Participants (i.e. most Spiegel clients) file an annual Form TO disclosing otherwise-unreported trade options. The rule would also provide relief from certain other recordkeeping and reporting requirements related to trade options.
The rulemaking offers an opportunity to submit comments in support of the proposed relief. Comments must be received by the CFTC by June 8, 2015.
Please see the full Client Alert attached to this page for further details.