Justification Statement for Non-Sustantive Revisions to CFTC Form TCR

MEMORANDUM
Date:

March 1, 2012

To:

Shagufta Ahmed and Nicholas Fraser, Office of Management and Budget (OMB),
Office of Information and Regulatory Affairs

From:

Vincente Martinez, Whistleblower Office,
Commodity Futures Trading Commission (CFTC)

Re:

Justification Statement for Non-Substantive Revisions to CFTC Form TCR

Attached are two revised versions of the CFTC’s Form TCR (OMB Control Number 3038-0082). The first
contains revisions to the form for use by complainants who prefer to complete a hard copy and submit it by mail or
facsimile. These are non-substantive changes to wording and formatting that are intended to make the form easier to
understand. For instance, throughout the form the term “the whistleblower” has been replaced with “you” to make
the questions clearer. The order of the questions in Section D of the form has also been changed to bring the most
important questions to the top of the section. A box to “Print Name of Attorney and Law Firm, if Applicable” has
also been added to Section G. The Privacy Statement, Submission Procedures and Instructions for Completing
Form TCR have also been edited to conform to the revisions in the form itself, and to update certain information,
such as the name of the correct office to which the form must be submitted. The Submission Procedures have also
been updated to reflect that complainants will have the ability to submit the form electronically through a CFTC web
portal, which is currently under development. Last, the form has been edited to correct spelling and grammar errors.
The second version contains the same questions and instructions, but is formatted for electronic submission
in the web portal. In order to make the form shorter, certain items will only appear if the complainant clicks on the
appropriate button, or selects “Yes” to a question that has follow-up sub-questions. The electronic form will also
contain hyperlinks to the Privacy Act Statement, Submission Procedures and Instructions for Completing Form TCR
so that a complainant can refer to those sections quickly as needed. Finally, the electronic form contains a checkbox
for the complainant to acknowledge that he/she has read and understands the Privacy Act Statement.
None of these revisions change the purpose of the form, or the content of the information collected.