Gregory Nowak

Gregory Nowak

Pepper Hamilton LLP

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Update: CFTC Delays Compliance Deadline for New Swap Margin Rules

Although the letter technically does not delay the effective date of March 1, 2017, from the perspective of the buy side, the letter functions as a “grace period,” and the compliance date has been moved to September 1, 2017....more

2/15/2017 - CFTC Financial Sector Margin Requirements Swap Dealers Swap Market Swaps

Documentation for the New Swap Margin Rules and Thoughts for the Buy Side and End Users

Because of the implementation of new regulatory requirements relating to both variation and initial margin for swaps, swap documentation for many market participants is about to become much more complicated....more

2/13/2017 - AIG Basel Committee CFTC Credit Support Annex (CSA) Dodd-Frank End-Users Financial Sector FX Swaps ISDA Jurisdiction Margin Requirements OTC Regulatory Standards SEC Securities Swap Dealers Swap Market Swaps

CFTC Grants Exemptive Relief to Private Fund Managers: General Solicitation Conditionally Permitted

The JOBS Act and the regulations thereunder (which went effective on September 23, 2013) applies to private issuers – including hedge funds and private equity funds – that want to make general solicitations within the context...more

9/18/2014 - CFTC Fund Managers General Solicitation JOBS Act Private Equity Private Funds Rule 506 Offerings

The Impact Of Rule 506(c) On Private Funds And Their Managers Who Are Legally Avoiding Full Registration As Commodity Pool...

The Jumpstart Our Business Startups Act (JOBS Act) directed the U.S. Securities and Exchange Commission (SEC) to eliminate the prohibition against general solicitation or general advertising in any offering of securities...more

9/5/2013 - CFTC Commodities Exchange Act Commodity Pool Fund Managers General Solicitation JOBS Act Private Equity Funds Private Funds Rule 506 Offerings SEC

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