Justification for Updated Form TCR

	U.S. COMMODITY FUTURES TRADING COMMISSION Three Lafayette Center 1155 21st Street, NW Washington, DC 20581
Whistleblower Office Fax: (202) 418-5975 Email: whistleblower@cftc.gov

M E M O R A N D U M

DATE: June 19, 2014

TO: Shagufta Ahmed and Nicholas Fraser, Office of Management and Budget (OMB),

Office of Information and Regulatory Affairs

FROM: Eduardo Martinez, Whistleblower Office

RE: Justification Statement for Revisions to CFTC Form TCR (printed version)

Attached is a revised version of the CFTC’s Form TCR (OMB Control Number 3038-0082). The attached form is for the use of complainants who prefer to complete a hard copy and submit it by mail or facsimile. This Form TCR merges the Division of Enforcement’s Complaint Form with the Whistleblower Office’s current Form TCR.

The majority of the changes are immaterial, as the merged form consolidates similar information requests into one question and maintains distinct questions/sections for dissimilar information requests. However, the merged form does have a new question. Question E8 requests the complainant’s consent to share his/her personally identifiable information to other governmental authorities, in accordance with 5 U.S.C. § 552a. A detailed review of the updated questions is below.

The Privacy Statement, Submission Procedures, and Instructions for Completing Form TCR have also been edited to conform to the revisions in the form itself. None of these revisions change the purpose of the form or the content of the information collected.

Section Review of the new Form TCR compared to the previous version:

• Section A: No change

• Section B: No Change

• Section C:

  • Numbering of each box has been updated so that each box now has an identifiable number

  • Question C14 is new

  • Question C15 is new

• Section D:

  • Questions D3 – D10 are new, yet similar to the old questions on the old Form TCR

• Section E:

  • Question E1 is the same question as D6 on the old Form TCR

  • Question E2 is the same question as D7 on the old Form TCR

  • Question E3 is the same question as D8a & D8b on the old Form TCR

  • Question E4 is the same question as D9a & D9b on the old Form TCR

  • Question E5 is the same question as D10a-d on the old Form TCR

  • Question E6 is the same question as D11a & D11b on the old Form TCR

  • Question E7 is the same question as D12 on the old Form TCR

  • Question E8 is new and requests the complainant’s consent to share his/her personally identifiable information to other governmental authorities, in accordance with 5 U.S.C. § 552a.

• Section F: Section F is the same as Section E on the old Form TCR

• Section G: Section G is the same as Section F on the old Form TCR

• Section H: Section H is the same as Section G on the old Form TCR