A Quick Look: CFTC’s first staff letter of 2021

In the first Commodity Futures Trading Commission (“CFTC”) staff letter of 2021, the CFTC’s Division of Clearing and Risk granted any DCO relief from daily reporting on individual customer accounts under the amended Regulation 39.19(c)(1) until January 27, 2022 as long as that DCO complies with the prior version of Regulation 39.19(c)(1). DCOs would otherwise have needed to report by the end of this month on each customer account’s initial margin requirements and margin held, daily variation margin required and held, any option premiums and payments, and end-of-day positions. This is more specific reporting than required previously under Regulation 39.19(c)(1), which required similar reporting by customer origin rather than by individual customer account. The CFTC staff’s one-year extension for compliance is in keeping with the CFTC’s overall response to the global pandemic, which has been understanding of operational limitations during state-mandated work from home.