Page 47 - 期货和衍生品行业监管动态（2023年9月刊）

期货和衍生品行业监管动态

difficulties associated with certain OCR reporting obligations that were identified by

reporting parties and market participants. The position announced today extends

DMO’s previously provided position under CFTC Letter No. 20-30, such that DMO

will not recommend the CFTC commence an enforcement action in the following

circumstances:

• Accurately reporting a trading account owner’s (TAC) and volume threshold

account (VTA) owner’s name within three business days following the day on

which the account became reportable;

• Failure to report certain TAC and VTA controller (VTAC) identifying

information;

• Failure to provide the level of confidence a reporting party has in the accuracy

of the information provided to it by its customers or counterparties;

• Failure to report a volume threshold account based on a reportable trading

volume level of 50 contracts (provided such reporting party reports instead based

on a reportable trading volume level of 250 or more contracts per day);

• Failure to report on Form 102S certain omnibus account originator and

consolidated account owner information (conditioned on electronically

reporting consolidated account counterparty information instead);

• Failure to report additional TAC and VTAC identifying information

(conditioned on DMO being able to obtain TAC-identifying information from

the special account controller and VTAC-identifying information from the VTA

owner or the reporting firm);

• Failure to submit refresh updates to Forms 102A, 102B, and 102S (conditioned

on filing timely and complete change updates);

• Use of the same contact information for all 10% owners and parent companies

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