CFTC asks traders whether its paperwork burden is worth it
Published Date: 10/22/2026
Notice
Summary
The Commodity Futures Trading Commission is asking for public feedback on a new information collection plan that could affect traders and businesses. They want your comments by November 23, 2026, to help decide if the paperwork is worth the time and cost. This review aims to keep things simple and fair while making sure the rules work well for everyone.
Analyzed Economic Effects
3 provisions identified: 0 benefits, 3 costs, 0 mixed.
Must keep written clearing documentation
If you are a swap dealer (SD), major swap participant (MSP), futures commission merchant (FCM), or derivatives clearing organization (DCO), you must develop and maintain written customer clearing documentation and trade processing procedures under the CFTC regulations. The rule cites recordkeeping obligations under 17 CFR 39.20 (DCOs), 23.606 (SDs and MSPs), and 1.73 (FCMs).
Estimated paperwork burden: 8,160 hours
The CFTC estimates the information collection covers 204 respondents with an average burden of 40 hours per respondent, for an estimated total annual burden of 8,160 hours. The notice states there are no capital costs or operating and maintenance costs associated with this collection.
Limits on arrangements that restrict clearing access
The Commission's regulations prohibit arrangements that would (a) disclose a customer's original executing counterparty, (b) limit the number of counterparties a customer may trade with, (c) restrict a customer's position size with an individual counterparty (apart from overall credit limits), (d) impair a customer’s access to execution on reasonably related best terms, or (e) prevent compliance with specified timeframes for acceptance into clearing. DCOs and clearing members must coordinate to establish prompt processing of trades.
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Key Dates
Department and Agencies
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