On June 4, 2018, the Commodity Futures Trading Commission (“CFTC” or “Commission”) by a 2 to 1 vote proposed to amend its regulations to maintain the de minimis exception threshold from swap dealer registration at the...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
On October 11, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) issued proposed rules to address certain issues related to the cross-border application of Title VII of the Dodd-Frank Wall Street Reform and...more
On May 24, 2016, the Commodity Futures Trading Commission (“CFTC”) in a much anticipated action approved the issuance of final rules (“Final Rules”) regarding the cross-border application of its uncleared swaps margin...more
6/8/2016
/ Basel Committee on Banking Supervision (BCBS) ,
CFTC ,
Commodities ,
Covered Swap Entities (CSE) ,
Cross-Border ,
Cross-Border Transactions ,
Federal Register ,
Final Rules ,
Financial Statements ,
Foreign Subsidiaries ,
Guaranty Claims ,
IOSCO ,
Margin Requirements ,
Prudential Regulation Authority (PRA) ,
Swap Dealers ,
Swaps ,
U.S. Person
On March 16, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) approved a final rule that eliminates the reporting and recordkeeping requirements in current CFTC regulations for trade option counterparties that are...more
On January 8, 2016, the Division of Clearing and Risk (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters providing relief from the mandatory clearing requirement for swaps under Section...more
On September 14, 2015, the Commodity Futures Trading Commission (CFTC) published a final rule requiring introducing brokers (IBs), commodity pool operators (CPOs), and most commodity trading advisors (CTAs) to become members...more
10/5/2015
/ CFTC ,
Commodity Exchange Act (CEA) ,
Commodity Trading Advisors (CTAs) ,
CPOs ,
De Minimus Quantity Exemption ,
Dodd-Frank ,
Final Rules ,
Introducing Brokers ,
National Futures Association ,
Registered Futures Association Membership ,
Swaps
On June 29, 2015, the Commodity Futures Trading Commission (“CFTC”) issued proposed rules (“Proposed Rules”) regarding the cross-border application of its proposed uncleared swaps margin rules issued last October. The...more
7/14/2015
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
CFTC ,
Commodities ,
Compliance ,
Cross-Border Transactions ,
Federal Register ,
Financial Statements ,
Foreign Subsidiaries ,
Futures ,
Margin Requirements ,
Proposed Regulation ,
Prudential Regulation Authority (PRA) ,
Public Comment ,
Swap Dealers ,
Swaps ,
U.S. Person
On May 12, 2015, the Commodity Futures Trading Commission (“CFTC”) and Securities and Exchange Commission (“SEC”) jointly issued the CFTC’s final interpretation clarifying its interpretation concerning forward contracts with...more
On April 30, 2015, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to the trade option exemption (the “Proposal”) that would reduce reporting and...more
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
On December 16, 2014, President Barack Obama limited the scope of swaps and security-based swaps subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (“Dodd-Frank Act’s”) pushout requirement to certain...more
12/23/2014
/ Asset-Backed Securities ,
Banking Sector ,
Banks ,
Barack Obama ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Foreign Banks ,
Push-Out Requirements ,
Section 716 ,
Swaps
On November 13, 2014, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) approved for publication in the Federal Register a proposed interpretation clarifying the CFTC’s...more
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 (PRA) ,
Public Comment ,
Swap Dealers ,
Swaps
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
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