Pursuant to Sections 4d(d) and 4s(k) of the Commodity Exchange Act (CEA), which were added to the CEA by the Dodd Frank Act, registered futures commission merchants, swap dealers and major swap participants (collectively, registrants) are obligated to designate an individual to serve as the entity’s chief compliance officer (CCO).  The duties and qualifications of such CCOs are set forth in CFTC Regulation 3.3.  Regulation 3.3(e) requires a CCO to “prepare a written report that covers the most recently completed fiscal year of the [registrant], and provide the annual report to the board of directors or the senior officer” and specifies the matters that must be covered by that report (Annual Report).  The first Annual Reports were recently submitted to the CFTC’s Division of Swap Dealer and Intermediary Oversight (Division).  Upon review of those Annual Reports, and after discussions with registrants, the Division has issued a Staff Advisory providing guidance to CCOs on completing Annual Reports.  The CFTC’s Annual Report requirement is in addition to the SEC requirement that investment advisers conduct a general annual compliance review.  See “How Hedge Fund Managers Should Approach Preparing For, Conducting and Documenting the Annual Compliance Review (Part One of Two),” Hedge Fund Law Report, Vol. 5, No. 12 (Mar. 22, 2012); and Part Two of Two.