Bridging the Week by Gary DeWaal: November 25 to December 6, and December 9, 2019 (CCO Annual Reports; Target Practice; Unintentional Breakdown)

Published Date: December 08, 2019

The Commodity Futures Trading Commission issued revised guidance for mandatory chief compliance officer annual compliance reports for futures commission merchants and swap dealers. However, the proposed recommendations are not as significant as a look-back on how compliance officers and CCO annual reports seemed to have become heightened targets of the CFTC’s Division of Enforcement in fiscal year 2019. Separately, a swap dealer was fined US $1 million by the CFTC for failing to make and retain audio recordings of certain oral communications of its swaps trading and related cash and forwards transactions for 20 business days. However, given the inadvertence of the incident and the firm’s self-discovery and response to its breakdown within just a few weeks, was this really a matter warranting an enforcement action, let alone a US $1 million fine? As a result, the following matters are covered in this week’s edition of Bridging the Week:

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Gary DeWaal

Gary DeWaal is currently Special Counsel with Katten Muchin Rosenman LLP in its New York office focusing on financial services regulatory matters. He provides advisory services and assists with investigations and litigation.

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Gary DeWaal
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