Blake Brockway

Blake Brockway

Katten Muchin Rosenman LLP

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NFA Announces New Filing Process for Swap Dealer and Major Swap Participant CCO Reports

On January 23, the National Futures Association (NFA) issued a notice informing its members that the annual reports required by NFA rules to be submitted by the chief compliance officer (CCO) of a swap dealer (SD) or major...more

2/5/2015 - Annual Reports CFTC Chief Compliance Officers Filing Requirements Major Swap Participants National Futures Association Portal Swap Dealers

Corporate and Financial Weekly Digest - Volume X, Issue 4

In this issue: - SEC Division of Corporation Finance Issues New C&DI Related to Resales Under Regulation S - SEC Announces Proxy Voting Roundtable - CFTC Staff Issues No-Action Relief From Certain...more

2/2/2015 - AIFM Anti-Money Laundering Brokers C&DIs CFTC Clawbacks CME NYMEX EU Directive Forex Insider Trading Major Swap Participants Netherlands No-Action Relief Proxy Voting Guidelines Regulation S Reporting Requirements SEC Swap Dealers UK

CFTC Staff Issues No-Action Relief Extending the Deadline for Certain CCO Annual Reports

On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that extends the deadline for submitting the annual report that must be...more

1/15/2015 - Annual Reports CFPB Chief Compliance Officers Corporate Officers DSIO FCMs Major Swap Participants No-Action Relief Swap Dealers Time Extensions

CFTC Staff Issues Guidance Regarding Chief Compliance Officer Annual Reports

On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued guidance regarding the annual reports that must be filed by the chief compliance officer (CCO)...more

1/14/2015 - Annual Reports CFTC Chief Compliance Officers DSIO FCMs Major Swap Participants Swap Dealers

CFTC Extends Relief to FCMs from Certain Commingling Requirements

On June 25, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) extended to October 31 the relief previously granted in CFTC No-Action Letters Nos. 14-02 and 14-45....more

7/2/2014 - CFTC Commingling DSIO FCMs No-Action Letters Swap Dealers Swaps

Corporate and Financial Weekly Digest - Volume IX, Issue 26

In this issue: - Delaware Fee-Shifting Legislation Delayed - SEC Orders Securities Exchanges and FINRA to Develop Tick Size Pilot Plan - CFTC Extends Relief to FCMs from Certain Commingling...more

6/30/2014 - CFTC FCMs Fee-Shifting Statutes FINRA Fraud-on-the-Market Halliburton v Erica P. John Fund NFA No-Action Letters SCOTUS SEC Securities Securities Fraud Shareholder Litigation Shareholders Swap Dealers Swaps

CFTC Extends No-Action Relief for Certain Transaction-Level Requirements for Non-US Swap Dealers

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01...more

6/10/2014 - CFTC Compliance DSIO No-Action Relief Swap Dealers Swap Market Swaps

Corporate and Financial Weekly Digest - Volume IX, Issue 23

In this issue: - SEC Chair Gives Speech on Equity Market Structure - New CFTC Commissioners Confirmed; Chairman Sworn In - CFTC Extends No-Action Relief for Certain Transaction-Level Requirements...more

6/9/2014 - CFTC Commodity Pool CPO Cross-Border Derivatives Clearing Organizations Equity Markets Fraud NFA No-Action Relief SEC Swap Dealers Swaps

CFTC Issues Interpretation Regarding Auditor Independence Standards

On March 28, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight issued an interpretive statement regarding the auditor independence standards applicable to futures commission...more

4/8/2014 - Auditors Audits CFTC FCMs Swap Dealers Swaps

CFTC Requests Comment on Staff Advisory Regarding the Applicability of Transaction Level Requirements

On January 3, the Commodity Futures Trading Commission requested public comment on the Division of Swap Dealer and Intermediary Oversight’s Advisory regarding the applicability of transaction-level requirements to non-US swap...more

1/15/2014 - CFTC Intermediaries Swap Dealers Swaps

CFTC Staff Extends No-Action Relief for Transaction-Level Requirements in Certain Cross-Border Situations

In an action parallel with the request for public comment (see “CFTC Requests Comment on Staff Advisory Regarding the Applicability of Transaction Level Requirements,” above), on January 3, the Commodity Futures Trading...more

1/15/2014 - CFTC Compliance Cross-Border DSIO No-Action Relief Swap Dealers

CFTC Issues Interpretive Guidance Regarding Certain Cross-Border Transactions

On July 12, the Commodity Futures Trading Commission adopted interpretive guidance and a policy statement regarding the cross-border application of the swap provisions of the Dodd-Frank Wall Street Reform and Consumer...more

7/23/2013 - CFTC Cross-Border Cross-Border Transactions Dodd-Frank Major Swap Participants Statutory Interpretation Swap Dealers Swaps

CFTC Staff Issues No-Action Letters

The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more

4/10/2013 - CFTC CPO Major Swap Participants No-Action Letters Recordkeeping Requirements Registration Swap Dealers Swaps

CFTC Issues Rule Regarding Persons Associated with Multiple Swap Dealers or Major Swap Participants

On April 1, the Commodity Futures Trading Commission issued a final rule clarifying that each swap dealer (SD), major swap participant (MSP) or other CFTC registrant with whom an associated person (AP) is associated is...more

4/10/2013 - CFTC Joint and Several Liability Major Swap Participants Swap Dealers

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