Julian Hammar

Julian Hammar

Morrison & Foerster LLP

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Prudential Regulators and CFTC Re-Propose Margin Requirement Rules for Uncleared Swaps

The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing Finance Agency...more

11/17/2014 - Banks CFTC Federal Reserve Foreign Banks Major Swap Participants Margin Requirements Proposed Regulation Prudential Regulation Authority Public Comment Swap Dealers Swaps

CFTC Excludes Certain Swaps with Utility Special Entities from the Special Entity De Minimis Calculation for Purposes of Swap...

On September 26, 2014, the Commodity Futures Trading Commission (“CFTC”) published a final rule in the Federal Register permitting a person to exclude “utility operations-related swaps” entered into with “utility special...more

10/10/2014

Harmony or Dissonance: The CFTC’s and SEC’s Cross-Border Rules

Recently, the SEC issued final rules addressing, among other things, the applicability of the security-based swap dealer (“SBSD”) and major security-based swap participant (“MSBSP”) definitions to cross-border security-based...more

7/10/2014 - CFTC Cross-Border Major Swap Participants MSBSPs SEC Swap Dealers Swaps

SEC Adopts Final Rules and Guidance Regarding the Cross-Border Application of “Security-Based Swap Dealer” and “Major...

Nearly four years after the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), on June 25, 2014, the Securities and Exchange Commission (“SEC”) adopted its first in a series of...more

7/7/2014 - Dodd-Frank Major Swap Participants SEC Security-Based Swaps Swap Dealers Swaps

Breaking the ISDA Section 2(a)(iii) Insolvency Stalemate

On 19 June 2014, the International Swaps and Derivatives Association (“ISDA”) published an amendment to the ISDA Master Agreement for use in relation to section 2(a)(iii) of that agreement, for parties who wish to amend their...more

7/2/2014 - Default Derivatives ISDA ISDA Master Agreement OTC

U.S. House Votes to Reauthorize the CFTC and Exclude Most RICs from CPO and CTA Requirements

The U.S. House of Representatives on June 24, 2014, passed a version of the CFTC reauthorization bill, H.R. 4413, that would exclude investment advisers to registered investment companies (RICs) from the definitions of...more

6/30/2014 - CFTC CPO CTA Investment Adviser Legislative Agendas Pending Legislation RICs

CFTC and FERC Issue Long-Awaited Memoranda of Understanding on Jurisdiction and Information Sharing

On January 2, 2014, the Commodity Futures Trading Commission (“CFTC”) and the Federal Energy Regulatory Commission (“FERC,” collectively, the “agencies”) signed “Memoranda of Understanding” regarding certain matters of...more

1/10/2014 - CFTC Dodd-Frank FERC Information Sharing Jurisdiction Memorandum of Understanding

CFTC Proposes Speculative Position Limits – Again

On November 5, 2013, the Commodity Futures Trading Commission (“CFTC” or “Commission”) proposed new speculative position limits. The proposal (“New Proposal”) would establish spot-month and non-spot-month limits for 28 core...more

11/20/2013 - CFTC Compliance Dodd-Frank Futures Position Limits

CFTC Staff Issues Commodity Option Frequently Asked Questions (“FAQs”)

On September 30, 2013, the CFTC’s Division of Market Oversight (“DMO”) issued a Commodity Option FAQ document. While the document largely contains information already set forth in prior CFTC releases, it does contain helpful...more

10/3/2013 - CEA CFTC Commodities Reporting Requirements Trade Options

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