Blake Brockway

Blake Brockway

Katten Muchin Rosenman LLP

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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

Joint Audit Committee Adopts Template Acknowledgment Letters

On March 12, the Joint Audit Committee issued a regulatory alert and revised templates for segregated, secured and cleared swap customer acknowledgment letters...more

3/19/2014 - CFTC FCMs Joint Audit Committee Swaps

CFTC Announces Available-to-Trade Determinations

In December 2013, Bloomberg LLC (BSEF) submitted a self-certified determination that certain interest rate and credit default swaps are made available to trade (MAT) for purposes of the Commodity Exchange Act (CEA) and...more

3/19/2014 - CEA CFTC Credit Default Swaps Swaps

CFTC Certifies Available-to-Trade Determinations

In October, TW SEF LLC (TW SEF) and MarketAxess SEF Corporation submitted self-certified determinations that certain interest rate and credit default swaps are made available to trade (MAT) for purposes of the Commodity...more

2/5/2014 - CFTC Commodities Exchange Act Credit Default Swaps Interest Rates 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 Seeks Comments on TW SEF Available-to-Trade Certification

On October 29, the Commodity Futures Trading Commission requested public comment on a made-available-to-trade certification submitted by TW SEF, LLC, a temporarily registered swap execution facility (SEF)...more

11/6/2013 - Certifications CFTC Commodities Exchange Act SEFs Swaps

CFTC Announces Mutual Acceptance of Approved Legal Entity Identifiers

On October 30, the Commodity Futures Trading Commission’s chief information officer announced that registered entities and swap counterparties subject to CFTC swap data recordkeeping and reporting requirements concerning...more

11/6/2013 - CFTC Legal Entity Identifiers Swaps

CFTC Staff Responds to FAQs Regarding Commodity Options

On September 30, CFTC staff issued responses to several frequently asked questions (FAQs) related to commodity options. Pursuant to Section 1a(47) of the Commodity Exchange Act, which defines the term “swap” to include an...more

10/9/2013 - CFTC Commodities Commodities Exchange Act Swaps Trade Options

CFTC Staff Issues No-Action Letters Relating to Swap Execution Facilities

Commodity Futures Trading Commission staff released several no-action letters impacting swap execution facilities (SEFs) and their participants. These no-action letters are related to swap data reporting requirements, SEF...more

10/8/2013 - CFTC No-Action Letters Reporting Requirements Risk Management SEFs Swaps

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 Extends No-Action Relief for Certain Transactions and Trading Platforms

On June 17, the Commodity Futures Trading Commission’s Division of Market Oversight extended the no-action relief it previously granted to any person or entity offering, entering into, or rendering advice or services with...more

6/25/2013 - CFTC Exemptions No-Action Letters SEFs Swaps

NFA Issues Notice to Members Regarding Section 16 Financial Requirements for Cleared Swaps Customer Collateral

On May 30, the National Futures Association issued a notice to its members regarding Section 16 of the NFA Financial Requirements. ...more

6/4/2013 - CFTC Customer Collateral Requirements NFA Notice Requirements Swap Clearing 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 Approves Clearing Exemption for Inter-Affiliate Swaps

On April 1, the Commodity Futures Trading Commission approved a final rule that permits certain affiliates to elect not to clear a swap. To qualify for the clearing exemption, the counterparties’ financial statements must be...more

4/10/2013 - CFTC Exemptions Final Rules Mandatory Clearing Requirements Reporting Requirements Swaps

CFTC Issues No-Action Letters

Staff of the Commodity Futures Trading Commission released a series of letters relating to a variety of regulatory changes, including the extraterritorial application of certain CFTC requirements, registration relief, swap...more

1/10/2013 - CFTC NFA No-Action Letters Swaps

CFTC Issues Final Order on Cross-Border Swaps

The Commodity Futures Trading Commission has issued a final exemptive order regarding the cross-border application of certain swaps provisions in the Dodd-Frank Wall Street Reform and Consumer Protection Act. Pursuant to the...more

1/10/2013 - CFTC Commodities Cross-Border Cross-Border Transactions Dodd-Frank Swaps

NFA Issues Guidance on Bylaw 1101 Compliance for Pending Introducing Brokers

On December 27, National Futures Association issued guidance for NFA members carrying accounts, accepting orders or handling transactions from an introducing broker (IB) whose NFA membership is pending in reliance upon...more

1/9/2013 - Brokers CFTC Compliance NFA No-Action Relief Swaps

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