The CFTC provides the market additional time to submit Form TO while considering further amendments to trade option reporting rules.

On February 18, 2016, the US Commodity Futures Trading Commission's (the CFTC) Division of Market Oversight (DMO) issued a no-action letter providing time-limited relief for end-users from the Form TO filing requirement under CFTC regulations (CFTC No-Action Letter 16-10).1 Though CFTC rules require counterparties to file a Form TO with the CFTC annually on March 1, reporting otherwise unreported trade options for the previous calendar year, the CFTC in 2015 proposed eliminating the Form TO filing requirement (the Proposed Trade Option Rules).2 While the CFTC is considering finalization of the Proposed Trade Option Rules, DMO will not recommend that the CFTC take enforcement action against a market participant that is neither a swap dealer (SD) nor a major swap participant (MSP) for failing to report its otherwise unreported trade options entered into during 2015 on Form TO.