Kenneth M. Rosenzweig

Kenneth M. Rosenzweig

Katten Muchin Rosenman LLP

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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 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 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 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

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

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