Guy C. Dempsey, Jr.

Guy C. Dempsey, Jr.

Katten Muchin Rosenman LLP

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Corporate and Financial Weekly Digest - Volume IX, Issue 6

In this issue: - SEC Division of Corporation Finance Issues Guidance on Rule 506(c) Private Placements - SEC Issues No-action Relief Regarding Registration of M&A Brokers - CFTC Issues Guidance on New...more

2/11/2014 - Alternative Investment Funds Bank Fraud Banks Brokers CFTC Due Diligence Exemptions Filing Requirements Fraud Investment Adviser Investment Funds No-Action Relief Private Placements Registration Rule 506 Offerings SEC Swap Dealers Swaps

CFTC Issues No-Action Relief from Certain Swap Data Reporting Requirements

The Commodity Futures Trading Commission’s Division of Market Oversight has issued temporary no-action relief to non-US swap dealers (SDs) and non-US major swap participants (MSPs) established in Australia, Canada, the...more

1/7/2014 - CFTC Cross-Border Major Swap Participants No-Action Relief Swap Data Repositories Swap Dealers

CFTC Delays Transaction-Level Requirements for Certain Non-US SD Transactions

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has delayed until January 14, 2014 the effectiveness its Advisory 13-69 issued on November 14 in which it took the position...more

12/11/2013 - CFTC DSIO Swap Dealers Swap Market Swaps

CFTC Adopts Rules for Segregation of Initial Margin for Uncleared Swaps

On October 31, the Commodity Futures Trading Commission adopted final rules with respect to the segregation of initial margin for uncleared swaps. The rules impose new obligations on swap dealers (SDs) and major swap...more

11/12/2013 - CFTC Commodities Exchange Act Major Swap Participants Margin Requirements Notice Requirements Segregation Requirements Swap Dealers Swaps

CFTC Provides Clarification for SD and MSP Employees Acting in Clerical or Ministerial Capacities

The Commodity Exchange Act and Commodity Futures Trading Commission regulations make it unlawful for a swap dealer (SD) or major swap participant (MSP) to permit a person subject to a statutory disqualification to effect or...more

11/1/2013 - CFTC Churches Major Swap Participants Swap Dealers Swaps

CFTC Extends Relief from De Minimis Exception to Certain Non-US Affiliates

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief to non-US persons that are not guaranteed or conduit affiliates of US persons (Non-Guaranteed Non-US...more

11/1/2013 - Affiliates CFTC No-Action Relief Swap Dealers Swaps

CFTC Issues Interpretive Guidance Regarding Certain Cross-Border Transactions

On July 12, the Commodity Futures Trading Commission adopted interpretive guidance and a policy statement regarding the cross-border application of the swap provisions of the Dodd-Frank Wall Street Reform and Consumer...more

7/23/2013 - CFTC Cross-Border Cross-Border Transactions Dodd-Frank Major Swap Participants Statutory Interpretation Swap Dealers Swaps

CFTC Grants No Action Relief to EU Swap Dealers from Swap Documentation Rules

Demonstrating coordination between US swap rules and those of the European Union, the Commodity Futures Trading Commission issued a no action letter (no. 13-45) on July 11 that permits a company organized under the laws of...more

7/17/2013 - CFTC EMIR EU Major Swap Participants No-Action Relief Required Documentation Swap Dealers Swaps

Federal Reserve Equalizes Treatment of Foreign Banks Under Dodd-Frank Push Out Rules

On June 5, 2013, the Federal Reserve Board approved an interim final rule designed to give uninsured US branches and agencies of foreign banks the same treatment as domestic depository institutions under section 716 of the...more

6/12/2013 - Dodd-Frank Federal Reserve Foreign Banks Swap Dealers

OCC Provides Guidance on Swap "Push-Out" Transition Periods

Section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act prohibits the provision of federal assistance to an insured depository institution that is a swap dealer unless the swap activities of that...more

1/9/2013 - Dodd-Frank OCC Swap Dealers Swaps

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