James M. Brady

James M. Brady

Katten Muchin Rosenman LLP

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NFA Reminds Members to Update Contact Information

National Futures Association (NFA) has issued a notice reminding members to keep current the information contained in NFA’s Online Registration System, including contact information for the member firm and individuals listed...more

5/20/2015 - National Futures Association Registration Requirement

CME Group Combines Block Trade Advisory Notices

CME Group has issued a market regulation advisory notice related to block trades that combines and supersedes similar advisory notices issued by (1) the Chicago Mercantile Exchange and the Chicago Board of Trade and (2) the...more

5/20/2015 - Block Trades CME CME NYMEX

CFTC Requests Public Comment on Nodal Clear’s DCO Application

The Commodity Futures Trading Commission has requested public comment on an application by Nodal Clear, LLC for registration as a derivatives clearing organization. Comments on the application may be submitted by June 8...more

5/19/2015 - CFTC Derivatives Clearing Organizations Public Comment

CFTC Revises Interpretation on Forward Contracts with Embedded Volumetric Optionality

In 2012, the Commodity Futures Trading Commission issued an interpretation that identifies the circumstances in which an agreement, contract or transaction would fall within the forward contract exclusions from the “swap” and...more

5/19/2015 - CFTC Commodities Exchange Act Forward Contracts Major Swap Participants Swap Dealers Swaps

Corporate & Financial Weekly Digest - Volume X, Issue 19

In This Issue: - FINRA's NAC Strengthens Sanction Guidelines Related to Fraud and Suitability - CFTC Revises Interpretation on Forward Contracts with Embedded Volumetric Optionality - CFTC Requests Public...more

5/18/2015 - Banking Sector Broker-Dealer CFTC Class Action CME DOJ Financial Institutions FINRA Virtual Currency

CFTC Proposal Eases Trade Option Obligations for Non-SD/MSP Counterparties

The Commodity Futures Trading Commission has proposed to amend part 32 of its regulations governing trade options to reduce the reporting requirements for counterparties that are not swap dealers or major swap participants...more

5/5/2015 - CFTC Counterparties Major Swap Participants Proposed Amendments Reporting Requirements Swap Dealers

Corporate & Financial Weekly Digest - Volume X, Issue 17

In this issue: - SEC Proposes New Pay-for-Performance Rules - NASAA Launches a Streamlined Filing Process for Form D - CFTC Proposal Eases Trade Option Obligations for Non-SD/MSP Counterparties -...more

5/4/2015 - Canada CFTC Exclusive Remedy Executive Compensation Form D Filing Forum Selection Clause Major Swap Participants NASAA Pay-for-Performance SEC Swap Dealers

CFTC and Australian Regulator Sign Memorandum of Understanding Regarding Cross-Border SDs and MSPs

The Commodity Futures Trading Commission and the Australian Prudential Regulation Authority (APRA) have entered into a memorandum of understanding regarding the supervision of CFTC-registered swap dealers and major swap...more

4/21/2015 - Australia CFTC Depository Institutions Major Swap Participants Memorandum of Understanding Prudential Regulation Authority Swap Dealers

CME Updates Order Routing/Front-End Audit Trail Requirements

The CME Group Exchanges have updated their recordkeeping requirements for order routing/front-end systems connected to the CME Globex platform through CME iLink. These updates include: (1) clarifying the scope of requirements...more

4/8/2015 - CFTC CME Order Routing Recordkeeping Requirements

CFTC Extends CCO Report Filing Deadline

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued permanent no-action relief from the filing deadline for chief compliance officer (CCO) annual reports....more

4/7/2015 - CFTC Chief Compliance Officers DSIO FCMs Filing Deadlines Major Swap Participants No-Action Relief Swap Dealers

CFTC Extends Portfolio Margining on ICE Clear Europe

The Commodity Futures Trading Commission has issued an amended order authorizing futures commission merchants (FCMs) that are not clearing members of ICE Clear Europe Limited, but carry futures and options on futures...more

4/7/2015 - Amended Order CFTC Clearing Members FCMs

CFTC Issues Relief to Swap Dealers Regarding Legacy SPV Swaps

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued no-action relief to swap dealers (SDs) from certain business conduct standards in dealing with...more

4/7/2015 - CFTC DSIO Legacy Funds No-Action Relief SPVs Swap Dealers

Corporate & Financial Weekly Digest - Volume X, Issue 13

In This Issue: - CFTC Extends Portfolio Margining on ICE Clear Europe - CFTC Extends CCO Report Filing Deadline - CFTC Issues Relief to Swap Dealers Regarding Legacy SPV Swaps - CME Updates Order...more

4/6/2015 - Annual Reports CFTC Chief Compliance Officers Class Action CME DSIO ESMA FCMs Filing Deadlines KBR (formerly Kellogg Brown & Root) Major Swap Participants Order Routing SEC SPVs Whistleblowers

CFTC Issues Advisory on Ownership and Control Reporting

The Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission have issued an advisory on ownership and control reporting (OCR) for futures...more

4/1/2015 - Advisory Opinions CFTC DSIO FCMs Market Participants No-Action Relief Reporting Requirements Swap Dealers

Corporate & Financial Weekly Digest - Volume X, Issue 12

In this issue: - SEC Adopts Final Rules for Regulation A+ Offerings - FINRA Issues Notice on New Rules and Amendments Relating to Transaction-Based Compensation, Membership and Sanctions - FINRA Issues...more

3/30/2015 - AIFMD Algorithmic Trading CFTC Final Rules FINRA New Guidance Pharmaceutical Manufacturers Regulation A Regulation SHO SEC Securities Fraud Supervision

CFTC to Host Roundtable on Cybersecurity and System Safeguards Testing

On March 18, Commodity Futures Trading Commission staff will hold a public roundtable on cybersecurity and system safeguards testing. The roundtable will focus on improving system safeguards testing requirements, including...more

3/10/2015 - Business Roundtable CFTC Cybersecurity

Corporate and Financial Weekly Digest - Volume X, Issue 9

In this issue: - Meeting of the SEC Advisory Committee on Small and Emerging Companies - Financial Action Task Force Publishes Updated List of Deficient Jurisdictions - CFTC to Host Roundtable on...more

3/9/2015 - CFTC Cybersecurity Destruction of Evidence EU FATF Foreign Banks Jurisdiction Risk Alert Sarbanes-Oxley SCOTUS SEC Small Business Volcker Rule

NFA Notifies SDs and MSPs of Annual Questionnaire Requirements

Beginning April 1, National Futures Association (NFA) will require its member swap dealers (SDs) and major swap participants (MSPs) to complete the SD-MSP Annual Questionnaire as part of its annual membership renewal process....more

2/25/2015 - Futures Major Swap Participants National Futures Association Swap Dealers

CFTC’s Energy and Environmental Markets Advisory Committee To Hold Meeting

The Commodity Futures Trading Commission’s Energy and Environmental Markets Advisory Committee will hold a meeting on February 26. The meeting, which will focus on the expected impact of the CFTC’s proposed position limit...more

2/24/2015 - CFTC Oil & Gas

CFTC Announces Members of Market Risk Advisory Committee

The Commodity Futures Trading Commission has announced the members of its Market Risk Advisory Committee (MRAC). The MRAC’s membership list is available...more

2/24/2015 - CFTC Derivatives

Corporate and Financial Weekly Digest - Volume X, Issue 7

In this issue: - CFTC’s Energy and Environmental Markets Advisory Committee To Hold Meeting - CFTC Announces Members of Market Risk Advisory Committee - NFA Notifies SDs and MSPs of Annual Questionnaire...more

2/23/2015 - CFOs CFTC Derivatives Dodd-Frank ESMA EU Financial Conduct Authority Financial Statements Foreign Exchanges MiFID II Sarbanes-Oxley SEC Stock Sale Agreements UK Whistleblowers

NFA Modifies EasyFile for Pool Annual Financial Statements

On February 10, National Futures Association (NFA) issued a notice to members describing minor changes to its EasyFile system for annual pool financial statement filings submitted by commodity pool operators (CPOs)...more

2/18/2015 - CPOs Electronic Filing Financial Statements NFA

CFTC Extends Relief From Certain OCR Requirements

The Division of Market Oversight of the Commodity Futures Trading Commission has extended no-action relief from certain of the CFTC’s ownership and control reporting (OCR) regulations, including electronic reporting via new...more

2/18/2015

Corporate and Financial Weekly Digest - Volume X, Issue 6

In this issue: - SEC Publishes Rules for Reporting Security-Based Swaps - SEC Proposes Rules for Disclosure of Companies’ Hedging Policies - CFTC Extends Relief From Certain OCR Requirements - NFA...more

2/17/2015 - Arbitration Banking Sector Banks Bribery Brokered Deposits Capital Requirements CFTC Clawbacks FDIC Haiti Hedging NFA OCC SEC Security-Based Swaps Subordination

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