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CFTC Brings Significant Enforcement Action Against Online Cryptocurrency Exchange

The action reflects the CFTC’s expanded jurisdiction and provides further clarity on what constitutes “actual delivery” in cryptocurrency trading. On June 2, 2016, the US Commodity Futures Trading Commission (CFTC)...more

Revised Rules on Dodd-Frank Incentive Compensation Requirements for Financial Institutions Proposed

If adopted, the Proposed Rule would have a significant impact on compensation practices at covered institutions. On April 21, 2016, the National Credit Union Administration (the NCUA) issued a proposed rule regarding...more

Dodd-Frank Almost 6 Years Later: Where Are We Now? Energy-Related Derivatives Regulation

In the almost six years since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the US Commodity Futures Trading Commission (CFTC) has, in large part, finalized its rulemakings...more

Dodd-Frank 5 Years Later: Where Are We Now? Derivatives Regulation for Asset Managers

Assessing the practical implications of derivatives regulations for investment advisers and investment funds of: position limits and aggregation rules, uncleared swaps margin rules, etc. Since the enactment of the...more

Prudential Regulators Are First to Finalize Uncleared Swap Margin Rules

While the rules provide some clarity, the global market still awaits the finalization of the CFTC and the European margin rules. With the clock ticking on the countdown to finalization of uncleared swap margin rules...more

CFTC Proposes Cross-Border Application of Margin Requirements for Uncleared Swaps

The CFTC has proposed rules that would define the reach of Dodd-Frank Act margin requirements in cross-border swap transactions. On June 29, 2015, the US Commodity Futures Trading Commission (CFTC) proposed regulations...more

Updated: CFTC Clarifies Regulation of Forward Contracts with Embedded Volumetric Optionality

With recent release, the CFTC hopes to eliminate market uncertainty on forward contracts with embedded volumetric optionality. UPDATE (June 18, 2015): On May 12, 2015, the CFTC adopted the Proposal as proposed (as used...more

SEC Proposes Additional Cross-Border Rules for Security-Based Swaps

If finalized, the proposed rule would be the SEC’s second major step toward finalizing the cross-border rules for security-based swaps under the Dodd-Frank Act. On April 29, 2015, the US Securities and Exchange...more

SEC Finalizes Partial Framework for the Cross-Border Application of its Derivatives Regulations

The SEC Final Rule is the SEC’s first major step toward implementing its final regulatory regime under Title VII of the Dodd-Frank Act. On June 25, 2014, the Securities and Exchange Commission (SEC) approved a final...more

Updated: CFTC FORM 40/40S Reporting Requirements

Note: This version includes an additional section on cross-border considerations. Significant amendments to the CFTC’s large trader reporting program will apply as of August 15, 2014. The U.S. Commodity...more

CFTC FORM 40/40S Reporting Requirements

Significant amendments to the CFTC’s large trader reporting program will apply as of August 15, 2014. The U.S. Commodity Futures Trading Commission (CFTC) has seemingly increased the number of Form 40/40S requests it...more

CFTC Re-Proposes Position Limits Rule and Proposes Revised Aggregation Requirements

The US Commodity Futures Trading Commission (CFTC), on November 5, 2013, re- proposed a rulemaking (the Re-­Proposed Rule) that would establish specific limits on speculative positions in 28 physical commodity futures and...more

CFTC Issues Guidance, Exemptions In Advance of SEF Rule Compliance Date

Staff responds to industry concerns and confusion surrounding SEF operations and onboarding. One of the key aspects of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) is...more

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