FIA submitted this letter in response to the Commodity Futures Trading Commission’s request for comment on its proposed amendments to the Commission’s large trader reporting rules, 17 CFR Parts 15-21, and related forms. The proposed amendments are designed to improve the Commission’s trade practice and market surveillance programs for futures and options on futures and to facilitate surveillance programs for swaps, by: (i) expanding the information currently collected on Form 102 (Identification of Special Accounts) and Form 40 (Statement of Reporting Trader); and (ii) introducing new reporting form for omnibus volume threshold accounts (Proposed Form 71). Further, the proposed amendments are intended to enhance the Commission’s ability to identify participants in the derivatives markets and to understand relationships among trading accounts, special accounts, reportable positions and market activity that otherwise appear unrelated.
