• CFTC Issues Fourth Penalty for Inaccurate Large Trader Reporting of Swaps
  • October 6, 2016 | Authors: Jonathan H. Flynn; Anthony M. Mansfield; Natalie Mitchell; Paul J. Pantano
  • Law Firm: Cadwalader, Wickersham & Taft LLP - Washington Office
  • On September 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) issued a fourth penalty for violations of its Swaps Large Trader Reporting (“Swaps LTR”) rule1. This time, the penalty was imposed against Wells Fargo Bank, N.A. (“Wells Fargo”). As we noted in July, the CFTC is continuing on its trend toward more aggressive enforcement of reporting violations, including violations of the particularly complex and technical Swaps LTR rule.2 Compliance professionals should continue to review their reporting processes, including Swaps LTR, to confirm that they conform to the CFTC rules.