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CFTC Approves Final Rule on Post-Trade Name Give-Up on Swap Execution Facilities

The CFTC has adopted a final rule to prohibit the controversial practice of post-trade name give-up for swaps that are executed anonymously through a Swap Execution Facility (SEF) and are intended to be cleared. Although the...more

ISDA Issues Consultation on Pre-Cessation Fallback Provisions to Facilitate LIBOR Transitioning

On February 25, 2020, the International Swaps and Derivatives Association (ISDA) launched a new consultation on how to implement pre-cessation fallback language into derivatives agreements. Responses are due by no later than...more

CFTC Approves Proposed Rule on Post-Trade Name Give-Up on Swap Execution Facilities

In the wake of significant market discussion, the CFTC has proposed an amendment to Part 37 of the Commission’s regulations to eliminate the practice of “post-trade name give-up” for swaps traded on certain swap execution...more

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more

CFTC Proposes Amendments to DCO Core Principle Regulations

The Commodity Futures Trading Commission (CFTC) has proposed a series of changes to its general regulations governing derivatives clearing organizations (DCOs). The CFTC has stated that the proposed amendments are intended to...more

CFTC Proposes Updated Swap Data Reporting Regulations

The Commodity Futures Trading Commission (CFTC) has proposed the first installment of a series of amendments to its rules relating to swap data repositories (SDRs) and reporting of swap data. The proposed amendments, which...more

CFTC Considers Revamp of SEF Regulatory Framework

Toward the end of 2018, the Commodity Futures Trading Commission (CFTC) proposed significant revisions to the framework governing swap trading through swap execution facilities (SEFs) and designated contract markets (DCMs)....more

CFTC Chair Outlines Further Steps to Swaps Trading Rules Reform

On April 26, 2018, Commodity Futures Trading Commission (CFTC) Chairman J. Christopher Giancarlo and Chief Economist Bruce Tuckman published a white paper on potential reforms to the CFTC’s swaps trading rules....more

A Corporate End User’s Handbook for Dodd-Frank Derivatives Compliance

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), signed into law on July 21, 2010, was the largest overhaul of the U.S. derivatives market in history. While there are still a few parts of Dodd-Frank...more

CFTC Adopts Final Rules Regarding the Cross-Border Application of Its Swap Margin Requirements

On May 24, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) adopted a final rule defining the cross border application of its margin requirements for uncleared swaps. The final rule covers all swap dealers and...more

Financial Regulatory Developments Focus - September 2015 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

CFTC Proposes New Approach to the Cross-Border Application of Margin Requirements

The US Commodity Futures Trading Commission (“CFTC”) has taken another step in refining its framework for cross-border activities, with a new set of proposed rules applicable to the cross-border application of margin...more

Initial Swap Trading Requirements Come into Effect—Limited Relief for Packaged Trades and Some EU Facilities

The Commodity Futures Trading Commission has imposed for the first time a requirement that certain swaps be traded on a regulated market. Beginning February 15, 2014, certain cleared interest rate swaps and index credit...more

Fed Rewrites Section 716 of Dodd-Frank

The Federal Reserve on Wednesday, June 5, issued an interpretation of the so-called “swaps push-out” section of the Dodd-Frank Act that corrects a drafting error that virtually everyone agrees needed to be fixed. The Federal...more

CFTC Swap Reporting No-Action Relief Granted; Other Dodd-Frank Deadlines Approaching

On April 9, 2013, the US Commodity Futures Trading Commission (the “CFTC”) granted last minute no-action relief from portions of the CFTC’s swap reporting rules. The relief delays certain compliance deadlines for many swap...more

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