Jeanette Curtis

Jeanette Curtis

Sutherland Asbill & Brennan LLP

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CFTC Affords Market Participants a “Second Bite” at the Swap Recordkeeping and Reporting Rules

Last month, the Commodity Futures Trading Commission (CFTC) issued a request for public comment on its swap data recordkeeping and reporting requirements under Part 45 of its regulations. The CFTC adopted Part 45 in 2012...more

4/3/2014 - CFTC Dodd-Frank Recordkeeping Requirements

CFTC Certifies Two More “Available to Trade” Determinations

Last week, the Commodity Futures Trading Commission (CFTC) certified two additional available to trade determinations (MAT determinations). The latest MAT determinations cover additional interest rate swaps (IRS) and, for the...more

2/6/2014 - CFTC Credit Default Swaps Interest Rate Swaps Swaps

Commodity Pool Operators and Commodity Trading Advisors: Are Enhanced Customer Protections on the Horizon?

On January 23, 2014, the National Futures Association (NFA) issued a Request for Comments from commodity pool operators (CPOs) and commodity trading advisors (CTAs) as to whether the NFA should adopt rules to: (1) ensure that...more

1/31/2014 - CFTC Compliance CPO CTA Deadlines Financial Regulatory Reform NFA

Legal Alerts: CFTC Certifies Additional “Available to Trade” Designation: Certain Interest Rate Swaps Must Be Executed on a SEF...

On Thursday, January 23, 2014, the Commodity Futures Trading Commission (CFTC) certified a second available to trade determination (the Second MAT Determination) in response to an application submitted by trueEX, LLC. ...more

1/28/2014 - CFTC SEFs Swap Dealers Swap Execution Facilities Swaps trueEX

Update: An End-User’s Guide to the CFTC’s Final Cross-Border Guidance

There were a number of new developments with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requirements for swaps in the latter part of 2013. This...more

1/22/2014 - CFTC Cross-Border Dodd-Frank End-Users EU ISDA SIFMA Swap Dealers Swaps

CPO and CTA Annual Affirmation of Exemptions Due in March

Pursuant to Commodity Futures Trading Commission (CFTC) regulations, persons claiming an exemption or exclusion from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA), under CFTC Regulations...more

1/22/2014 - CFTC Compliance CPO CTA Exemptions

CFTC Certifies First “Available to Trade” Designation: Certain Interest Rate Swaps Must be Executed on a SEF or DCM Beginning on...

As market participants are aware, certain swaps that are subject to mandatory clearing must be executed on a registered swap execution facility (SEF) or a designated contract market (DCM) (i.e., an exchange) once a swap is...more

1/17/2014 - CFTC Securities SEF Swaps

Legal Alert: Final Volcker Rule: Update and Key Takeaways

On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission and the Commodity Futures...more

1/13/2014 - Bank Holding Company Act Banks CFTC Collateralized Debt Obligations Compliance Dodd-Frank FDIC Federal Reserve OCC Proprietary Trading Trust Preferred Securities Volcker Rule

Federal Agencies Issue Final Volcker Rule

On December 10, 2013, five federal agencies, including the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the...more

12/16/2013 - Banks CFTC Compliance Dodd-Frank FDIC OCC SEC Volcker Rule

An End-User's Guide to the CFTC's Final Cross-Border Guidance

Last month, the U.S. Commodity Futures Trading Commission (CFTC) issued final interpretive guidance with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank...more

8/9/2013 - Affiliates CFTC Cross-Border Dodd-Frank End-Users Exemptive Orders Major Swap Participants Swap Dealers Swaps

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