Key takeaways

• The Division of Market Oversight of the CFTC has issued time-limited no-action relief relating to the Ownership and Control ("OCR") Final Rule, adopted in 2013 to enhance the CFTC's identification of futures and swaps market participants.
• CFTC Letter 16-32 replaces a prior no-action letter, further extending the existing relief from certain reporting requirements under Parts 17, 18 and 20 of the CFTC regulations that were added by the OCR Final Rule, and grants additional relief to address certain reporting issues.
• CFTC Letter 16-33 permits parties with reporting obligations on OCR Forms 102A and 102B to mask certain identifying information, subject to certain conditions and for a limited duration.