On July 1, 2020, five U.S. prudential regulators published in the Federal Register two separate rulemakings containing significant amendments of the margin rules for non-cleared swaps applicable to swap dealers that are...more
On December 17, 2019, three different divisions of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters intended to facilitate the swaps market’s transition away from interbank offered rates (each, an...more
On November 7, 2019, five U.S. prudential regulators published in the Federal Register significant amendments (including the accompanying release, the “PR Amendments”) that they are proposing to modify the margin rules (the...more
In this issue of Structured Thoughts, we discuss:
..The SEC’s newly released margin rules for security-based swap dealers.
..U.K.’s Financial Conduct Authority consultation on its proposal to ban the sale, marketing, and...more
On April 26, 2018, J. Christopher Giancarlo, Chairman of the Commodity Futures Trading Commission (“CFTC” or “Commission”) and Bruce Tuckman, the CFTC’s Chief Economist, issued a white paper outlining changes to swaps...more
Last week the Commodity Futures Trading Commission (“CFTC”) issued an order (the “De Minimis Order”) that pushes back by one year the date on which the CFTC may lower its swap dealer de minimis threshold, the amount of swap...more
Last month the Commodity Futures Trading Commission (“CFTC”) released the final report of its staff (the “Staff”) on the de minimis exception to the CFTC’s definition of “swap dealer” (the “Final Report”). That exception,...more
More than six years after the enactment of the Dodd-Frank Act, and more than three years after the US Commodity Futures Trading Commission (CTFC) required swap dealers to register in accordance with Title VII of that Act, it...more
Early this month the U.S. Securities and Exchange Commission (“SEC”) released final rules (the “Registration Rules”) for the registration of security-based swap dealers (“SBSDs”). The Registration Rules, released more than...more
8/31/2015
/ Background Checks ,
Broker-Dealer ,
CFTC ,
Chief Compliance Officers ,
Compliance ,
Final Rules ,
Policies and Procedures ,
Registration ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
Security-Based Swaps ,
Stand-Alone SBSDs ,
Swaps
Last fall both the Commodity Futures Trading Commission (“CFTC”) and five U.S. prudential banking regulators (the “Prudential Regulators”) released proposed rules for margin requirements for uncleared swap transactions for...more
After years of anticipation, the U.S. Commodity Futures Trading Commission in July 2013 issued more than 300 pages of “guidance” ostensibly to assist market participants in understanding the breadth of the extraterritorial...more
7/15/2014
/ CFTC ,
Cross-Border ,
Cross-Border Transactions ,
Dodd-Frank ,
EU ,
Extraterritoriality Rules ,
G20 ,
Market Participants ,
Over The Counter Derivatives (OTC) ,
Swap Market ,
Swaps
At their September 2009 summit in Pittsburgh, G20 leaders agreed that by no later than December 2012, all standardised over-the-counter (OTC) derivatives should be traded on exchanges or electronic trading platforms ‘where...more