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Kenneth M. Rosenzweig

Kenneth M. Rosenzweig

Katten Muchin Rosenman LLP


Latest Posts › CFTC

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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 Multilateral Portfolio Compression No-Action Relief 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

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

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

CFTC Extends Compliance Dates for Certain Swap Dealer and Major Swap Participant Requirements

The Commodity Futures Trading Commission has issued interim final rules extending the effective dates for certain business conduct and documentation requirements for swap dealers (SDs) and major swap participants (MSPs)...more

12/28/2012 - CFTC Compliance Major Swap Participants Swap Dealers Swaps

CFTC Issues No-Action Letters Relating to Swaps

Commodity Futures Trading Commission Staff have released several no-action letters relating to various requirements associated with swap trading, including swap dealer (SD) reporting requirements, SD chief compliance officer...more

12/28/2012 - CFTC Compliance Natural Gas No-Action Letters Swap Dealers Swaps

SEC Issues Exemptive Order in Connection with Portfolio Margining of Cleared Swaps and Security-Based Swaps

Provisions of the Securities Exchange Act of 1934 (Exchange Act) and the Commodity Exchange Act (CEA) preclude market participants from portfolio margining collateral and other property that is required by the Exchange Act...more

12/27/2012 - Broker-Dealer CEA CFTC Dodd-Frank SEC Swaps

CFTC Issues No-Action Letters

The Commodity Futures Trading Commission (CFTC) released a series of staff letters relating to various issues arising under rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, including chief...more

12/18/2012 - CFTC CPO Dodd-Frank FX Swaps No-Action Letters Swaps

CFTC Issues No-Action Relief from CPO Registration

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission issued three no-action letters granting relief from commodity pool operator (CPO) registration for operators of certain...more

12/12/2012 - CFTC No-Action Relief Swap Dealers

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