The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) announced a streamlined approach for requesting relief from the commodity pool operator (“CPO”) registration requirement for a CPO that delegates...more
The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) issued an interpretive letter regarding the auditor independence standards included in CFTC Regulation 1.16, specifically as it applies to...more
The SEC has proposed standards for “covered clearing agencies,” which would include registered clearing agencies that (i) have been designated as systemically important by the Financial Stability Oversight Council and for...more
The CFTC has issued two separate no-action relief letters to provide time-limited no-action relief pertaining to swaps between certain affiliated counterparties. The letters both pertain to CFTC Regulation 50.52, which...more
The CFTC’s Division of Swap Dealer and Intermediary Oversight issued a Staff Advisory outlining recommended best practices for covered financial institutions to comply with Title V of the Gramm-Leach-Bliley Act of 1999...more
The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more
The Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the “Agencies”) adopted an interim final rule (the “Interim Rule”) that provides relief from certain requirements of the Volcker rule for...more
1/15/2014
/ Bank Holding Company Act ,
Banks ,
CFTC ,
Collateralized Debt Obligations ,
Compliance ,
Dodd-Frank ,
FDIC ,
OCC ,
Securities and Exchange Commission (SEC) ,
Trust Preferred Securities ,
Volcker Rule
The CFTC has determined that certain entity-level swap requirements of six non-U.S. jurisdictions are generally “comparable” to those of the Commodity Exchange Act and CFTC regulatory regime. ...more
The Securities Industry and Financial Markets Association (“SIFMA”), International Swaps and Derivatives Association (“ISDA”), and Institute of International Bankers (“IIB”) filed a suit against the CFTC in the U.S. District...more
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Securities and Exchange Commission jointly adopted and the Commodity Futures Trading Commission...more
12/13/2013
/ Banks ,
CFTC ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Hedge Funds ,
Market Making ,
OCC ,
Private Equity ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
The National Futures Association (the “NFA”) has issued guidance reminding market participants of CFTC regulations that require any person claiming an exemption or exclusion under CFTC Regulation 4.5, 4.13(a)(1), 4.13 (a)(2),...more
The National Futures Association (the “NFA”) issued Notice to Members I-13-36 (the “NFA Notice”) which is directed at any commodity pool operator (“CPO”) of a registered investment company (a “RIC”) that has filed a notice...more
The CFTC announced that registered entities and swap counterparties subject to the CFTC’s jurisdiction may now comply with the CFTC’s swap data recordkeeping and reporting requirements with respect to Legal Entity Identifiers...more
The CFTC approved final rules requiring enhanced protections afforded customers and customer funds held by futures commission merchants (“FCMs”). The rules require FCMs to adopt and enforce a risk management program,...more
The CFTC has proposed a rule that would require all registered introducing brokers (“IBs”), commodity pool operators (“CPOs”), and commodity trading advisors (“CTAs”) to be members of a registered futures association (“RFA”)....more
The CFTC voted on Tuesday to propose a new position limits rule that would establish limits on speculative positions in physical commodity futures contracts. The CFTC’s previous position limits rule was vacated last year by...more
The National Futures Association (the “NFA”) announced that amendments to Compliance Rule 2-46 that require commodity trading advisors (“CTAs”) to report to the NFA on a quarterly basis will be effective beginning with the...more
The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) granted no-action relief (the “No-Action Relief”) in response to a request from the Investment Company Institute (the “ICI”) and the Securities...more
In IM Guidance Update No. 2013-05, the staff of the SEC’s Division of Investment Management provided further guidance on disclosure and compliance matters relating to the use of derivatives by registered funds. The Guidance...more
The CFTC adopted rule amendments (the “Harmonization Rule”) designed to harmonize certain CFTC compliance obligations that apply to commodity pool operators (“CPOs”) of investment companies registered under the Investment...more