Earning self-reporting credit from the Commodity Futures Trading Commission (CFTC) is no simple task, the agency’s enforcement director conceded.

Voluntary self-disclosure is only the first step, Ian McGinley reminded an audience of legal experts during a keynote address delivered at an industry event Thursday. From there, a firm must cooperate and remediate as well for the chance to earn full credit from the agency.

“Self-reporting, cooperation, and remediation implicate the importance of trust in these negotiations, which is a two-way street—the regulator’s reliance on the entity to be truthful and fully cooperative and the entity’s reliance on the regulator to account for the self-report in good faith,” he said.