Securities Regulation Daily Wrap Up, CFTC NEWS AND SPEECHES—CFTC staff grants 18-month no-action relief for 2024 large trader reporting rule, (Jan 29, 2026)
The relief ties enforcement to the completion of testing, guidance updates, and industry calls, with staff expecting full compliance by July 26, 2027.
The CFTC’s Division of Market Oversight issued a no-action letter providing temporary enforcement relief from the compliance date of the 2024 Part 17 large trader reporting final rule. Acting on a request from the futures industry’s principal trade association, staff said it will not recommend enforcement action against futures commission merchants, clearing members, foreign brokers, or designated contract markets that do not meet the rule’s June 3, 2026 compliance date. The no-action relief is designed to preserve the approximately 18-month testing period that the CFTC contemplated when it adopted the rule (CFTC Staff Letter, No. 26-02 (Jan. 27, 2026)).
Rule changes and industry concerns. The final rule updated the data submission standards and required data elements for large trader position reports. Industry participants sought relief after the expected testing timeline slipped, citing the unavailability of the updated CFTC reporting portal, the need for implementation discussions with staff, and the pending revision of the Part 17 Guidebook. Staff agreed that, without relief, reporting firms would have less than the intended time to test new reporting formats and systems before being required to comply.
Compliance timeline. Under the no-action position, enforcement will be deferred until 18 months after three milestones are completed: the start of CFTC staff implementation calls with industry, the public availability of the reporting portal for testing, and publication of a revised Part 17 Guidebook. During this period, reporting firms must continue to submit reports under the pre-June 3, 2024 Part 17 requirements. The Division of Data has begun updating the Guidebook, announced implementation testing, and scheduled industry calls beginning February 18, with staff indicating an expectation that market participants will achieve compliance by July 26, 2027.
This is CFTC Staff Letter No. 26-02.
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