CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") Director Joshua B. Sterling described the DSIO's "Five Building Blocks" that make up the DSIO's approach to a "complete regulatory program." Mr. Sterling said that with respect to:

  1. the Examination Program, the DSIO is working closely with NFA to establish a program of targeted thematic reviews. The reviews will focus on certain large swap dealers and CPOs beginning in the first quarter of 2020;
  2. the Reporting Framework, the DSIO is actively assessing the CFTC data reporting regimes, and supporting CFTC Commissioner Dawn D. Stump's ongoing efforts to review reporting issues;
  3. the Guidance Program, the DSIO is improving data analysis of registrant reviews. Mr. Sterling explained that the DSIO will clarify expectations of registrants concerning compliance requirements and stated that the DSIO expects to decrease the use of letter relief for specific parties and, instead, provide guidance applicable to all relevant market participants;
  4. Enforcement, the DSIO is strengthening its relationship with the Division of Enforcement by focusing on referrals of non-compliant registrants; and
  5. Rulemaking, the DSIO intends to use the insights from the Building Blocks program as input on future rule amendments.

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