On the compliance side, the requirements vary based on the size of the banking entity and the scope of activities conducted. On the one hand, the final rules reduce the burden on smaller, less complex institutions by limiting their compliance and reporting requirements, and a banking entity that does not engage in covered trading activities will not have to establish a compliance program. On the other hand, banking entities with significant trading operations will be required to establish a detailed compliance program and undertake independent testing and analysis of that compliance program. In addition, their CEOs will need to attest that the program is reasonably designed to achieve compliance with the final rules.
See also additional statements by the CFTC.