Kenneth M. Rosenzweig

Kenneth M. Rosenzweig

Katten Muchin Rosenman LLP

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Foreign Listed Stock Index Futures and Options Approval Chart April 16, 2014

Attached please find the updated Foreign Listed Stock Index Futures and Options Approvals Chart, current as of April 16, 2014. All prior versions are superseded and should be discarded. Please note the following developments...more

4/16/2014 - CFTC Economic Development Foreign Exchanges Futures Stocks

CFTC Issues Guidance Regarding Swap Execution Facilities

On November 14, the Commodity Futures Trading Commission’s Divisions of Clearing and Risk, Market Oversight and Swap Dealer and Intermediary Oversight (the Divisions) issued guidance to swap execution facilities (SEFs) and...more

11/19/2013 - CFTC Eligible Contract Participant SEFs Swaps

CFTC Issues Cross-Border Transactions Advisory

On November 14, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission issued Advisory No. 13-69 to answer inquiries on whether a registered non-US swap dealer (SD) must...more

11/19/2013 - CFTC Cross-Border Foreign Branches of U.S. Banks Swap Dealers Swaps

CFTC Extends Time-Limited Relief for Foreign Exchange Swaps

The Commodity Futures Trading Commission’s Division of Market Oversight issued No-Action Letter No. 13-68, which extends to November 29 the deadline set forth in CFTC No-Action Letters 13-55, 13-56 and 13-58 for swap...more

11/12/2013 - CFTC Foreign Exchanges SEFs Swaps

CFTC Approves Position Limits Proposals

The Commodity Futures Trading Commission has proposed amendments to its existing speculative position limit regulations. The proposed amendments, which are being published in two separate releases, are being re-proposed by...more

11/12/2013 - CFTC Position Limits

CFTC Adopts Final Harmonization Rules for Registered Investment Company Advisers Required to Register as CPOs Under Regulation...

On August 13, 2013, the Commodity Futures Trading Commission issued its final rules (“Final Rules”) applicable to registered investment companies now required to dually register as commodity pool operators (“Dually-Registered...more

8/21/2013 - CFTC Commodities Commodity Pool CPO CTA Investment Companies Registration SEC

NFA Issues Reminder of FCM Responsibility for Review of Guaranteed IB Promotional Materials

In response to an increase in the volume of promotional material being submitted by guaranteed introducing brokers (GIBs) to the National Futures Association (NFA) through its Pre-review Program (a free service offered by the...more

4/3/2013 - FCMs Guaranteed Introducing Brokers NFA

Court Rules FERC Does Not Have Authority to Fine Trader for Manipulation of Futures Contracts

Pursuant to the Energy Policy Act of 2005, the Federal Energy Regulatory Commission (FERC) fined a natural gas trader $30 million for manipulating the settlement price for natural gas futures contracts on the New York...more

3/26/2013 - CFTC FERC Futures Natural Gas

CFTC Grants Relief from Required Clearing for Swaps Resulting from Multilateral Portfolio Compression

On March 18, the Commodity Futures Trading Commission’s Division of Clearing and Risk granted no-action relief relating to the clearing requirement for swaps resulting from multilateral portfolio compression exercises (as...more

3/26/2013 - CFTC Mandatory Clearing Requirements No-Action Relief Portfolio Compression Swaps

CFTC Grants Relief from Required Clearing for Partial Novation and Partial Termination of Swaps

On March 20, the Commodity Future Trading Commission’s Division of Clearing and Risk granted no-action relief from the clearing requirement for “stub” swaps that result when two counterparties agree to reduce the notional...more

3/26/2013 - CFTC Mandatory Clearing Requirements No-Action Relief Novation Stub Swaps Termination

FCMs Required to Have Chief Compliance Officer by March 29

Commodity Futures Trading Commission Regulation 3.3, which requires each futures commission merchant (FCM) to designate a chief compliance officer (CCO), will become effective on March 29, 2013 in respect of FCMs that are not...more

3/20/2013 - CFTC Chief Compliance Officers Compliance FCMs NFA Reporting Requirements

CFTC Reminds Market Participants of Swap Data Reporting Requirements

The Commodity Futures Trading Commission’s Division of Market Oversight issued an advisory to remind market participants that pursuant to Parts 43 and 45 of the CFTC’s regulations, swap dealers were required to begin...more

3/20/2013 - CFTC Recordkeeping Requirements Reporting Requirements Swaps

CFTC Approves CME Swap Data Reporting Rule

On March 6, the Commodity Futures Trading Commission approved the Chicago Mercantile Exchange Inc.’s (CME) request to adopt CME Rule 1001. CME Rule 1001 addresses the CME’s obligation, in its capacity as a derivatives...more

3/13/2013 - CFTC CME Derivatives Clearing Organizations Reporting Requirements Swap Data Repositories Swaps

NFA Proposes Amendment Permitting Certain Loans by Commodity Pools to Related Entities

On March 4, the National Futures Association (NFA) issued a proposed rule change and interpretive notice that would allow commodity pools to provide certain loans to related commodity pool operators (CPOs) and other...more

3/13/2013 - Commodity Pool CPO NFA

CFTC Revises Clearing Compliance Schedule for iTraxx CDS Indices

The Division of Clearing and Risk of the Commodity Futures Trading Commission has deferred for approximately six weeks the deadline for mandatory clearing of iTraxx Credit Default Swap (iTraxx CDS) indices. Swap dealers,...more

3/6/2013 - CFTC Compliance iTraxx CDS indices

CFTC Permits Cantor Clearinghouse to Clear Certain Foreign Exchange Options

On February 11, the Commodity Futures Trading Commission issued an amended order that allows Cantor Clearinghouse, L.P. (Cantor), a registered derivatives clearing organization, to clear...more

2/19/2013 - Cantor Clearinghouse CFTC Derivatives Clearing Organizations Foreign Exchanges Option Contracts

trueEX Requests that CFTC Amend Order of Designation as a Contract Market

The Commodity Futures Trading Commission is seeking public comment regarding a request by trueEX LLC (trueEX) to amend its order of designation as a contract market...more

2/13/2013 - CFTC trueEX

NFA to Require CPOs to Identify Registered Investment Companies

The National Futures Association (NFA) has notified its members that it will require each member of the NFA that is registered as a commodity pool operator (CPO) and operates one or more commodity pools that are also...more

2/6/2013 - CFTC CPO Investment Companies NFA Registration

CFTC to Host Roundtable on Enhancing Customer Funds Protection

The Commodity Futures Trading Commission staff will host a public roundtable to discuss the CFTC’s proposed rulemaking, “Enhancing Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and...more

2/6/2013 - CFTC Customer Funds Protection Derivatives Derivatives Clearing Organizations

NFA Sets Implementation Deadline for Phase 1 of Customer Segregated Funds Reporting

The National Futures Association (NFA) recently amended Section 4 of its Financial Requirements to require futures commission merchants (FCMs) that hold customer funds to in turn require banks and trust companies holding such...more

2/6/2013 - NFA Reporting Requirements Segregated Funds Third-Party

CFTC Issues Exemptive Order to ICE Clear Credit Permitting Commingling and Portfolio Margining of Cleared Credit Default Swaps and...

The Commodity Futures Exchange Commission has issued an exemptive order (Order) that permits the commingling and portfolio margining of cleared credit default swaps (CDS) and security-based swaps (SB CDS)...more

1/23/2013 - Broker-Dealer CDS CEA CFTC Commingling SB CDS Swaps

CFTC Issues No-Action Letters

Staff of the Commodity Futures Trading Commission released a series of letters relating to a variety of regulatory changes, including the extraterritorial application of certain CFTC requirements, registration relief, swap...more

1/10/2013 - CFTC NFA No-Action Letters Swaps

CFTC Issues Final Order on Cross-Border Swaps

The Commodity Futures Trading Commission has issued a final exemptive order regarding the cross-border application of certain swaps provisions in the Dodd-Frank Wall Street Reform and Consumer Protection Act. Pursuant to the...more

1/10/2013 - CFTC Commodities Cross-Border Cross-Border Transactions Dodd-Frank Swaps

NFA Issues Guidance on Bylaw 1101 Compliance for Pending Introducing Brokers

On December 27, National Futures Association issued guidance for NFA members carrying accounts, accepting orders or handling transactions from an introducing broker (IB) whose NFA membership is pending in reliance upon...more

1/9/2013 - Brokers CFTC Compliance NFA No-Action Relief Swaps

Exemption from NFA Assessment Fee for Proprietary Trading Firms that Register as CPOs

The National Futures Association (NFA) has issued a notice temporarily exempting certain proprietary trading firms that may be required to be registered as commodity pool operators (CPOs) as of December 31, 2012, from the...more

12/28/2012 - CFTC CPO NFA

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