Adam J. Spector

Adam J. Spector

Katten Muchin Rosenman LLP

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Corporate and Financial Weekly Digest - Volume IX, Issue 14

In this issue: - SEC Requests Comment on FINRA Rules - CFTC Issues Interpretation Regarding Auditor Independence Standards - OTC Derivatives Regulators Group Issues Report to G20 - NFA...more

4/7/2014 - Auditors Audits CFTC FATF FINRA G20 NFA ORC SEC Securities Fraud Virtual Currency

Corporate and Financial Weekly Digest - Volume IX, Issue 11

In this issue: - NASDAQ Launches Marketplace for Private Companies - SEC Proposes Rules to Enhance Oversight of Clearing Agencies - FINRA Proposes to Amend Rules 2210 and 2214 - CME Group Exchanges...more

3/17/2014 - Audits CFTC Clearing Agencies CME FINRA Nasdaq Ponzi Scheme Risk Management SEC Transfers

CFTC Issues No-Action Relief to FCMs Relating to Enhanced Customer Protection Rules

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued two no-action letters granting relief to futures commission merchants (FCMs) from certain requirements of the...more

1/21/2014 - Broker-Dealer CFTC Compliance FCMs No-Action Letters Swap Dealers Swaps

Corporate and Financial Weekly Digest - Volume IX, Issue 3

In this issue: - CFTC Issues No-Action Relief to FCMs Relating to Enhanced Customer Protection Rules - Eleventh Circuit Upholds Directors’ Affirmative Defenses Based on FDIC’s Post-Receivership Conduct -...more

1/20/2014 - Affirmative Defenses Banks CFTC Collateralized Debt Obligations Directors FCMs FDIC Insider Trading No-Action Relief OCC Professional Liability Receivership Scienter Trust Preferred Securities

CFTC Grants LCH.Clearnet Time-Limited No-Action Relief to Clear Swaps Executed on DCMs or SEFs

The Commodity Futures Trading Commission’s Division of Clearing and Risk (DCR) has granted time-limited no-action relief stating that it will not recommend that the CFTC take enforcement action against (i) LCH.Clearnet Ltd...more

10/1/2013 - CFTC LCH.Clearnet.LLC No-Action Relief Swaps

Mandatory Clearing of iTraxx CDS Indices for Category 2 Entities Began July 25

The Division of Clearing and Risk of the Commodity Futures Trading Commission announced that commodity pools, private funds (other than active funds) and certain other persons predominantly engaged in banking or financial...more

7/30/2013 - CFTC Commodity Pool iTraxx CDS indices Major Swap Participants Private Funds Swap Dealers Swaps

CFTC Issues Extension of Time-Limited No-Action Relief to Cooperatives

The Division of Clearing and Risk of the Commodity Futures Trading Commission has extended the expiration date for relief granted in an earlier no-action letter from the swap clearing requirement under Section 2(h) of the...more

7/30/2013 - CFTC No-Action Letters Swap Clearing Swaps

CFTC Staff Issues New and Extends Current No-Action Relief

The Commodity Futures Trading Commission recently released two no-action letters (i) extending relief provided to futures commission merchants (FCMs) relating to risk-based limits for bunched orders and (ii) providing relief...more

6/11/2013 - CFTC Future Commission Merchants Mandatory Clearing Requirements No-Action Letters Swaps

CFTC Staff Issues No-Action Letters

Commodity Futures Trading Commission staff recently released two no-action letters providing relief relating to the application of business conduct standards to prime brokers and swap dealers and disclosure of pre-trade...more

5/7/2013 - Business Conduct Standards CFTC Commodities Exchange Act Disclosure Requirements No-Action Letters Swap Dealers

CFTC Staff Issues No-Action Letters

Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more

4/16/2013 - CFTC End-Users Major Swap Participants No-Action Letters Recordkeeping Requirements Reporting Requirements Swap Dealers Swaps Trade Options

CFTC Issues Proposed Rule to Clarify Responsibilities of Clerical Employees of SDs and MSPs

In general, Commodity Futures Trading Commission Regulation 23.22 prohibits a swap dealer (SD) or major swap participant (MSP) from permitting an associated person (AP) of the SD or MSP to effect or be involved in effecting...more

4/16/2013 - Background Checks CFTC Major Swap Participants Proposed Regulation Swap Dealers

FCMs Required to Have Chief Compliance Officer by March 29

Commodity Futures Trading Commission Regulation 3.3, which requires each futures commission merchant (FCM) to designate a chief compliance officer (CCO), will become effective on March 29, 2013 in respect of FCMs that are not...more

3/20/2013 - CFTC Chief Compliance Officers Compliance FCMs NFA Reporting Requirements

CFTC Reminds Market Participants of Swap Data Reporting Requirements

The Commodity Futures Trading Commission’s Division of Market Oversight issued an advisory to remind market participants that pursuant to Parts 43 and 45 of the CFTC’s regulations, swap dealers were required to begin...more

3/20/2013 - CFTC Recordkeeping Requirements Reporting Requirements Swaps

CFTC and IOSCO to Host Roundtable on IOSCO Financial Benchmarks Report

Staff of the Commodity Futures Trading Commission, in conjunction with the International Organization of Securities Commissioners (IOSCO), will host a public roundtable to discuss IOSCO’s recently published Consultation...more

2/26/2013 - Benchmarks CFTC IOSCO

NFA to Require CPOs to Identify Registered Investment Companies

The National Futures Association (NFA) has notified its members that it will require each member of the NFA that is registered as a commodity pool operator (CPO) and operates one or more commodity pools that are also...more

2/6/2013 - CFTC CPO Investment Companies NFA Registration

CFTC to Host Roundtable on Enhancing Customer Funds Protection

The Commodity Futures Trading Commission staff will host a public roundtable to discuss the CFTC’s proposed rulemaking, “Enhancing Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and...more

2/6/2013 - CFTC Customer Funds Protection Derivatives Derivatives Clearing Organizations

CFTC Issues Exemptive Order to ICE Clear Credit Permitting Commingling and Portfolio Margining of Cleared Credit Default Swaps and...

The Commodity Futures Exchange Commission has issued an exemptive order (Order) that permits the commingling and portfolio margining of cleared credit default swaps (CDS) and security-based swaps (SB CDS)...more

1/23/2013 - Broker-Dealer CDS CEA CFTC Commingling SB CDS Swaps

CFTC Grants No-Action Relief for Certain Cleared Repo Transactions

The Division of Clearing and Risk (DCR) of the Commodity Futures Trading Commission has adopted a no-action position authorizing registered futures commission merchants (FCMs) to enter into repurchase and reverse repurchase...more

12/4/2012 - CFTC No-Action Relief

CFTC Grants Temporary No-Action Relief from Clearing Requirement for Swaps Between Affiliated Counterparties

The Division of Clearing and Risk (DCR) of the Commodity Futures Trading Commission issued temporary no-action relief from the swaps clearing requirement for swaps that are entered into between affiliated counterparties...more

12/4/2012 - CFTC Swaps

CFTC Requests Comment on CME Swap Data Reporting Rules

The Commodity Futures Trading Commission has requested comment on rules submitted by the Chicago Mercantile Exchange (CME) that would require the CME’s clearing house to report all creation and continuation data to the CME’s...more

12/4/2012 - CFTC CME Swap Data Repositories

CFTC Grants Temporary No-Action Relief from Swap Data Reporting Rules

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission issued temporary no-action relief to swap dealers (SDs) from certain requirements of Parts 43, 45 and 46 of CFTC regulations...more

12/4/2012 - CFTC Swap Dealers

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