On May 7,the CFTC published in the Federal Register a proposal to eliminate the odd-yet-burdensome Form TO, which for the past two years has been required of derivatives end-users to report certain information to the CFTC regarding their trading in commodity trade options.

If the proposal is adopted as final after the close of the comment period on June 8, few will mourn the passing of Form TO. One requirement that the CFTC retained for trade options was reporting.

But it was quite a byzantine reporting regime. In the typical scenario, under Rule Form TO was an odd Form right from the start.

Thus, if an end-user does not enter into any trade options with other end-users during the year, it is not required to file a Form TO even if it exercises a substantial number of trade options during the same year. Conversely, if an end-user enters into a trade option with another end-user during the year, it must file a Form TO that is devoid of information if it does not exercise any trade options during the same year.

Nevertheless, how to analyze a binary options successfully CFTC viewed Form TO as an accommodation to end-users that objected to applying the Part 45 swap reporting rules to trade options.

After all, Form TO requires only the aggregate trade options dodd frank values of trade options exercised in a given calendar year if any to be reported, whereas Part 45 bee options binary broker reviews require the reporting of significant detail regarding the date, time, parties, etc.

What the CFTC did not appreciate at the time, though, was the burden trade options dodd frank Form TO places on end-users required to file it.

In its recent proposal to eliminate From TO, the CFTC noted the comments it had options arbitrage strategies pdf explaining that, because trade options are physical delivery instruments, the systems and processes used by many end-users to create, store, and track their trade options are separate and distinct from their financial systems, and typically are not designed to track the kind of information required by Form TO.

The proposal would eliminate Form TO in its entirety — there are no circumstances in which it still would be required. Nor would end-users be required to report trade options under the Part 45 swap reporting rules.

Eliminating Form TO would go far towards re-focusing the CFTC on the causes of the financial crisis, and away from its overzealous emphasis on commercial businesses that often were its victims. Norton Rose Fulbright, LLP Norton Rose Fulbright, LLP Location Global Africa Asia Australia Canada Germany Italy The Netherlands United Kingdom United States Global.

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