Daphne G. Frydman

Daphne G. Frydman

Sutherland Asbill & Brennan LLP

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Regulators Publish Re-proposed Margin Requirements for Uncleared Swaps

On September 3, 2014, the Board of Governors of the Federal Reserve System (the Board) jointly adopted, with certain federal banking regulators, re-proposed rules that will require registered swap dealers, security-based swap...more

9/25/2014 - Banks Basel Committee CFTC Dodd-Frank Federal Reserve IOSCO Major Swap Participants Margin Requirements Prudential Regulation Authority SEC Swap Dealers Swap Market Swaps

Storm Clouds Continue to Gather Over Bankruptcy Code’s Safe Harbors

As noted in a previous Sutherland Legal Alert, the American Bankruptcy Institute has formed a Commission to Study the Reform of Chapter 11 (the Commission). To further its goal of proposing changes to modernize the Bankruptcy...more

5/30/2014 - Bankruptcy Code Chapter 11 Commercial Bankruptcy Debtors-in-Possession Dodd-Frank FDIA Safe Harbors Title II

CFTC Affords Market Participants a “Second Bite” at the Swap Recordkeeping and Reporting Rules

Last month, the Commodity Futures Trading Commission (CFTC) issued a request for public comment on its swap data recordkeeping and reporting requirements under Part 45 of its regulations. The CFTC adopted Part 45 in 2012...more

4/3/2014 - CFTC Dodd-Frank Recordkeeping Requirements

Legal Alert: Final Volcker Rule: Update and Key Takeaways for Private Funds

On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission, and the Commodity Futures...more

1/15/2014 - Antitrust Provisions Bank Holding Company Act Banks CFTC Collateralized Debt Obligations Dodd-Frank FDIC Federal Reserve OCC Private Funds Proprietary Trading SEC Volcker Rule

Legal Alert: Final Volcker Rule: Update and Key Takeaways for Insurers

On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the Commodity Futures Trading...more

1/15/2014 - Bank Holding Company Act Banks CFTC Collateralized Debt Obligations Dodd-Frank Federal Reserve OCC Proprietary Trading SEC Trust Preferred Securities Volcker Rule

FIO Report Sets the Agenda for Discourse on the Future of Insurance Regulation

On December 12, 2013, the Federal Insurance Office (FIO) of the U.S. Department of the Treasury released its much anticipated study, How to Modernize and Improve the System of Insurance Regulation in the United States...more

1/15/2014 - Dodd-Frank Federal Insurance Office Insurance Companies Insurance Reform Insurers NAIC Title V

Legal Alert: Final Volcker Rule: Update and Key Takeaways

On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission and the Commodity Futures...more

1/13/2014 - Bank Holding Company Act Banks CFTC Collateralized Debt Obligations Compliance Dodd-Frank FDIC Federal Reserve OCC Proprietary Trading Trust Preferred Securities Volcker Rule

Federal Agencies Issue Final Volcker Rule

On December 10, 2013, five federal agencies, including the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the...more

12/16/2013 - Banks CFTC Compliance Dodd-Frank FDIC OCC SEC Volcker Rule

An End-User's Guide to the CFTC's Final Cross-Border Guidance

Last month, the U.S. Commodity Futures Trading Commission (CFTC) issued final interpretive guidance with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank...more

8/9/2013 - Affiliates CFTC Cross-Border Dodd-Frank End-Users Exemptive Orders Major Swap Participants Swap Dealers Swaps

Legal Alert: Nearly at the Buzzer, CFTC Affords End-Users Relief from Dodd-Frank Reporting Requirements

On the brink of the compliance date for arguably one of the most burdensome requirements that end-users face under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Commodity Futures Trading...more

4/22/2013 - CFTC Dodd-Frank End-Users Reporting Requirements Swaps

Legal Alert: ISDA Accepting Comments on Draft Dodd-Frank "Protocol 2.0"

Pursuant to Title VII of the Dodd-Frank Wall Street Reform and Customer Protection Act (Dodd-Frank), the Commodity Futures Trading Commission (CFTC) has adopted a number of final regulations that require swap dealers (SDs)...more

2/6/2013 - CFTC Derivatives Dodd-Frank ISDA Major Swap Participants Protocol 2.0 Swap Clearing Swap Dealers Swaps Title VII

Legal Alert: The CPO and CTA Regulatory Regimes: What Operators of and Advisers to Commodity Pools Should Expect in 2013

There were a number of significant changes to the regulatory regime for commodity pool operators (CPOs) and commodity trading advisors (CTAs) in 2012. As a result of these changes, various types of collective investment...more

1/18/2013 - CFTC Commodities Commodity Pool CPO CTA Dodd-Frank Fund of Funds Investment Firms Swap Dealers Swaps

CFTC Extends Compliance Dates for Dodd-Frank Requirements Necessitating Amendments to Existing Trade Documentation

On December 18, the Commodity Futures Trading Commission (CFTC), by private vote, adopted interim final rules (Interim Final Rules) to amend the compliance dates for previously issued final rules that establish external...more

12/24/2012 - Business Conduct Standards CFTC Compliance DF-Protocol Dodd-Frank ISDA Major Swap Participants Swap Dealers

CFTC Issues No-Action Relief from Commodity Pool Operator Registration Requirements for Business Development Companies

On December 4, 2012, the Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from commodity pool operator (CPO) registration requirements for...more

12/6/2012 - CFTC Commodity Pool Dodd-Frank Investment Advisers Act of 1940 No-Action Relief Swaps

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