Key takeaways

• The CFTC has adopted final rules eliminating the reporting and recordkeeping requirements applicable to entities that are not swap dealers or major swap participants and that enter into trade options.
• Specifically, the final rules eliminate the Form TO annual notice reporting requirement and the reporting and recordkeeping requirements in part 45 of the CFTC regulations for non-SD/MSP trade option counterparties.
• Non-SD/MSP counterparties are still required to obtain an LEI and provide such LEI to their SD/MSP counterparties.