Ian Cuillerier

Ian Cuillerier

White & Case LLP

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The Delta Report – Derivatives Newsletter: September 2016

In this issue of The Delta Report, we bring you further updates on developments in the global derivatives space. In Europe, the focus is on Brexit and the newly-released EU final regulatory standards on the valuation of...more

9/24/2016 - Asia Bail-In Provisions Bankruptcy Court BRRD CFTC Collateralized Debt Obligations Cross-Border Derivatives Dodd-Frank Electric Generation Suppliers EMIR End-Users EU Final Rules Germany Hong Kong ISDA Mandatory Clearing Requirements Margin Requirements Natural Gas Netting Agreements OTC SEC Singapore Swaps Trade Options UK Brexit Uncleared Swaps

CFTC Rule 3.10(c)(3): CFTC proposed amendments

On July 27, 2016 the Commodity Futures Trading Commission ("CFTC") released proposed amendments to the exemption from registration as an IB, a CTA or a CPO contained in CFTC Rule 3.10(c)(3) that remove the clearing...more

8/30/2016 - CFTC Commodities Exchange Act CPOs CTA Dodd-Frank Exemptive Relief International Finance Introducing Brokers Proposed Amendments Swap Dealers Swaps

CFTC Issues Final Rules on Cross-Border Uncleared Swap Margin Requirements

The CFTC has combined an entity-level approach with a transaction-level approach in its final cross-border uncleared swap margin requirements. Introduction - On December 16, 2015, the Commodity Futures Trading...more

8/10/2016 - CFTC Cross-Border Dodd-Frank Entity Classification Final Rules Major Swap Participants Margin Requirements Swap Dealers Swaps Uncleared Swaps

The Delta Report - June 2016

White & Case LLP is proud to introduce the first edition of our derivatives newsletter, The Delta Report. In each issue, we will highlight recent key regulatory developments across the Americas, Europe and Asia and discuss...more

6/22/2016 - CFTC Derivatives EU ISDA Margin Requirements No-Action Relief Non-US Entities OTC RTS SEC SFTR Singapore Swap Trading Uncleared Swaps

No-Action Relief from CFTC Rule 3.10(c)(3) Clearing Requirement

CFTC grants no-action relief regarding the application of the exemption in CFTC Rule 3.10(c)(3) to swaps that are not subject to a clearing requirement. On February 12, 2016 the Commodity Futures Trading Commission...more

3/10/2016 - Brokers CFTC CPOs CTA Dodd-Frank DSIO Exemptions Mandatory Clearing Requirements No-Action Relief Swaps

Prudential Regulators and CFTC: Final Margin Rules for Uncleared Swaps

The Prudential Regulators and the CFTC release final initial and variation margin rules for uncleared swaps and security-based swaps. On October, 22 2015, the Prudential Regulators released final rules and accompanying...more

3/8/2016 - CFTC Covered Swap Entities (CSE) End-Users Final Rules Major Swap Participants Margin Requirements Prudential Regulation Authority Security-Based Swaps Swaps Terrorism Insurance Uncleared Swaps

CFTC Issues Proposed Rules on Cross-Border Uncleared Swap Margin Requirements

The CFTC has combined an entity-level approach with a transaction-level approach in its proposed cross-border uncleared swap margin requirements. Introduction - On October 3, 2014, the Commodity Futures Trading...more

7/16/2015 - Advanced Notice of Proposed Rulemaking (ANPRM) CFTC Cross-Border Dodd-Frank Major Swap Participants Margin Requirements Swap Dealers Swaps U.S. Person

Final Exemptive Order Regarding Cross-Border Application of Certain Swap Regulations

On July 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) approved a second final exemptive order (the “Final Order”) providing time-limited relief from certain cross-border applications of the swaps provisions...more

8/23/2013 - CFTC Dodd-Frank Major Swap Participants Swap Dealers Swaps Title VII

CFTC Approves Final Interpretative Guidance With Respect To The Cross-Border Application Of Certain Swap Provisions Of The...

Introduction - On July 12, 2013, the Commodity Futures Trading Commission (the “CFTC” or the “Commission”) approved final interpretative guidance (the “Final Guidance”)1 regarding the cross-border application of...more

8/22/2013 - CFTC Commodities Exchange Act Compliance Cross-Border Major Swap Participants Swap Dealers Swaps

CFTC Approves Final Regulations Governing Clearing Exemption for Swaps Between Certain Affiliated Entities and Provides No-Action...

On April 1, 2013, the Commodity Futures Trading Commission (“CFTC”) approved a final rule (Regulation 50.52) exempting swaps between certain affiliated entities from the clearing requirements of the Commodity Exchange Act...more

6/3/2013 - CEA CFTC Derivatives Clearing Organizations Dodd-Frank GAAP IFRS Mandatory Clearing Requirements No-Action Letters Reporting Requirements Swaps

The CFTC Issues Interim Final Rules Extending the Time for Compliance with Certain Business Conduct and Documentation Requirements...

On December 18, 2012, the US Commodity Futures Trading Commission’s (the “Commission”) approved interim final rules (the “Interim Final Rules”) for swap dealers (“SDs”) and major swap participants (“MSPs”) that delay...more

1/11/2013 - CFTC Dodd-Frank Major Swap Participants Required Documentation Swap Dealers Swaps

Final Exemptive Order Regarding Compliance With Certain Swap Regulations; Further Proposed Guidance

On December 21, 2012, the Commodity Futures Trading Commission (the “Commission” or “CFTC”) approved an exemptive final order (the “Final Order”) providing time-limited relief from certain cross-border applications of the...more

1/3/2013 - CEA CFTC Cross-Border Transactions Dodd-Frank Swaps

The CFTC Issues Interim Final Rules Extending the Time for Compliance for Certain Business Conduct and Documentation Requirements...

On December 18, 2012, the US Commodity Futures Trading Commission’s (the “Commission”) approved interim final rules (the “Interim Final Rules”) for swap dealers (“SDs”) and major swap participants (“MSPs”) that delay...more

12/29/2012 - Business Conduct Standards CFTC Compliance Dodd-Frank ISDA Major Swap Participants Required Documentation Swap Dealers Swaps

The CFTC and the Division of Swap Dealer and Intermediary Oversight Publishes a Series of No-Action Letters, Q&As and Faqs

In the space of a few days in mid-October, the Commodity Futures Trading Commission (the “CFTC”) published a number of Q&As and FAQs and the CFTC staff at the Division of Swap Dealer and Intermediary Oversight (the...more

12/5/2012 - CFTC No-Action Letters Swap Dealers

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