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Kevin M. Foley

Kevin M. Foley

Katten Muchin Rosenman LLP


Latest Publications

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CFTC Adopts Final Rules for Execution Facilities and Other Matters

During an open meeting on May 16, the Commodity Futures Trading Commission adopted a final rule establishing core principles and other requirements for swap execution facilities, which will become effective 60 days after...more

5/21/2013 - CFTC Final Rules Swap Execution Facilities

CFTC Staff Issues No-Action Letters

Commodity Futures Trading Commission staff recently released two no-action letters providing relief relating to the application of business conduct standards to prime brokers and swap dealers and disclosure of pre-trade...more

5/7/2013 - Business Conduct Standards CFTC Commodities Exchange Act Disclosure Requirements No-Action Letters Swap Dealers

NFA Amends CPO and CTA Quarterly Reporting Requirements

On April 24, the National Futures Association (NFA) issued a notice to members regarding amendments to NFA Compliance Rule 2-46. The amended rule modifies the NFA’s quarterly pool reporting requirements and extends related...more

4/30/2013 - Amended Regulation CFTC Commodity Trading Advisers CPO NFA Reporting Requirements

NFA Amends FCM Capital Requirements for Forex Transactions with ECPs

The National Futures Association (NFA) has amended the financial requirements applicable to member futures commission merchants (FCMs) acting as counterparties in foreign exchange (forex) transactions...more

4/26/2013 - Amended Regulation Eligible Contract Participant Forex Future Commission Merchants NFA

ICE Clear Europe Authorized to Portfolio Margin Swaps and Security-Based Swaps

The Commodity Futures Trading Commission issued an order (Order) permitting ICE Clear Europe Limited (ICE Clear Europe) and its clearing members that are registered both as broker-dealers under the Securities Exchange Act of...more

4/17/2013 - Broker-Dealer Credit Default Swaps Securities Exchange Act Swap Clearing Swaps

CFTC Staff Issues No-Action Letters

Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more

4/16/2013 - CFTC End-Users Major Swap Participants No-Action Letters Recordkeeping Requirements Reporting Requirements Swap Dealers Swaps Trade Options

CFTC Issues Proposed Rule to Clarify Responsibilities of Clerical Employees of SDs and MSPs

In general, Commodity Futures Trading Commission Regulation 23.22 prohibits a swap dealer (SD) or major swap participant (MSP) from permitting an associated person (AP) of the SD or MSP to effect or be involved in effecting...more

4/16/2013 - Background Checks CFTC Major Swap Participants Proposed Regulation Swap Dealers

CME Block Trade Advisories Clarify Nonpublic Information Restrictions

In two recent market regulation advisory notices (RA1303-3 and RA1307-4), CME Group clarified its rules regarding the disclosure and use of nonpublic information based upon a solicitation to participate in a block trade. The...more

4/16/2013 - Block Trades CME Disclosure Requirements Material Nonpublic Information

CFTC Staff Issues No-Action Letters

The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more

4/10/2013 - CFTC CPO Major Swap Participants No-Action Letters Recordkeeping Requirements Registration Swap Dealers Swaps

CFTC Issues Rule Regarding Persons Associated with Multiple Swap Dealers or Major Swap Participants

On April 1, the Commodity Futures Trading Commission issued a final rule clarifying that each swap dealer (SD), major swap participant (MSP) or other CFTC registrant with whom an associated person (AP) is associated is...more

4/10/2013 - CFTC Joint and Several Liability Major Swap Participants Swap Dealers

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

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 and IOSCO to Host Roundtable on IOSCO Financial Benchmarks Report

Staff of the Commodity Futures Trading Commission, in conjunction with the International Organization of Securities Commissioners (IOSCO), will host a public roundtable to discuss IOSCO’s recently published Consultation...more

2/26/2013 - Benchmarks CFTC IOSCO

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

NFA Issues Notice Regarding CTA Reporting Requirements

National Futures Association (NFA) issued a notice to members relating to reporting requirements for commodity trading advisors (CTAs)...more

1/31/2013 - Commodities CTA Investment Adviser NFA Reporting Requirements

CFTC Amends Order of Registration and Approves Rulebook for LCH.Clearnet LLC

The Commodity Futures Trading Commission issued an amended order of registration to LCH.Clearnet LLC (LCH LLC), formerly the International Derivatives Clearinghouse, LLC. LCH LLC’s parent company, LCH.Clearnet Group Limited,...more

1/30/2013 - CEA CFTC LCH.Clearnet.LLC

CFTC to Host Roundtable on "Futurization" of Swaps

Commodity Futures Trading Commission staff will host a public roundtable to discuss the “futurization” of swaps...more

1/29/2013 - CFTC 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

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

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