Kevin M. Foley

Kevin M. Foley

Katten Muchin Rosenman LLP

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NFA Notifies SDs and MSPs of Annual Questionnaire Requirements

Beginning April 1, National Futures Association (NFA) will require its member swap dealers (SDs) and major swap participants (MSPs) to complete the SD-MSP Annual Questionnaire as part of its annual membership renewal process....more

2/25/2015 - Futures Major Swap Participants National Futures Association Swap Dealers

CFTC’s Energy and Environmental Markets Advisory Committee To Hold Meeting

The Commodity Futures Trading Commission’s Energy and Environmental Markets Advisory Committee will hold a meeting on February 26. The meeting, which will focus on the expected impact of the CFTC’s proposed position limit...more

2/24/2015 - CFTC Oil & Gas

CFTC Announces Members of Market Risk Advisory Committee

The Commodity Futures Trading Commission has announced the members of its Market Risk Advisory Committee (MRAC). The MRAC’s membership list is available...more

2/24/2015 - CFTC Derivatives

NFA Increases Minimum Security Deposits for Forex Transactions

The Executive Committee of the National Futures Association (NFA) has temporarily increased the minimum security deposits required to be collected and maintained by forex dealer members (FDMs) for foreign exchange...more

2/5/2015 - Foreign Exchanges Forex National Futures Association Security Deposits

NFA Announces New Filing Process for Swap Dealer and Major Swap Participant CCO Reports

On January 23, the National Futures Association (NFA) issued a notice informing its members that the annual reports required by NFA rules to be submitted by the chief compliance officer (CCO) of a swap dealer (SD) or major...more

2/5/2015 - Annual Reports CFTC Chief Compliance Officers Filing Requirements Major Swap Participants National Futures Association Portal Swap Dealers

CFTC Staff Issues No-Action Relief From Certain Financial Reporting Requirements Applicable to Introducing Brokers

On January 23, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter regarding financial reporting requirements as they apply to foreign introducing...more

2/3/2015 - CFTC DSIO Foreign Entities Introducing Brokers No-Action Letters Reporting Requirements

CME Group Exchanges Revise Position Limit Rules

The Chicago Mercantile Exchange, Chicago Board of Trade, New York Mercantile Exchange and Commodity Exchange have revised their position limit rules by removing provisions that formerly deemed a market participant to have...more

2/3/2015 - CME CME NYMEX Market Participants Position Limits

Corporate and Financial Weekly Digest - Volume X, Issue 4

In this issue: - SEC Division of Corporation Finance Issues New C&DI Related to Resales Under Regulation S - SEC Announces Proxy Voting Roundtable - CFTC Staff Issues No-Action Relief From Certain...more

2/2/2015 - AIFM Anti-Money Laundering Brokers C&DIs CFTC Clawbacks CME NYMEX EU Directive Forex Insider Trading Major Swap Participants Netherlands No-Action Relief Proxy Voting Guidelines Regulation S Reporting Requirements SEC Swap Dealers UK

NFA Increases Minimum Security Deposits for Forex Transactions

National Futures Association (NFA)’s Executive Committee has temporarily increased the minimum security deposits required to be collected and maintained by Forex Dealer Members (FDMs) for foreign exchange transactions...more

1/27/2015 - Foreign Exchanges Forex NFA Security Deposits

CFTC Grants Order of Registration to Tokyo Commodity Exchange

The Commodity Futures Trading Commission has issued an order granting the Tokyo Commodity Exchange––an exchange subject to the regulatory supervision of the Japanese Ministry of Economy, Trade and Industry and the Ministry of...more

1/27/2015 - CFTC Market Participants Registration Tokyo Commodity Exchange

China Regulator Proposes to Permit Designated Domestic Futures Contracts to be Traded by Foreigners

The China Securities Regulatory Commission (CSRC) is soliciting public comment on proposed rules (Interim Measures) that would open Chinese futures markets to direct trading by non-Chinese persons apparently for both...more

1/26/2015 - CSRC Foreign Nationals Futures People's Bank of China Proposed Regulation

CFTC Staff Extends No-Action Relief to Certain Reporting Counterparties Masking Identifying Information Pursuant to Non-US Law

On January 8, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) granted an extension of previously issued no-action relief for parties required to report identifying...more

1/20/2015 - CFTC Counterparties DSIO No-Action Relief Swap Dealers

CFTC Staff Issues No-Action Relief Extending the Deadline for Certain CCO Annual Reports

On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that extends the deadline for submitting the annual report that must be...more

1/15/2015 - Annual Reports CFPB Chief Compliance Officers Corporate Officers DSIO FCMs Major Swap Participants No-Action Relief Swap Dealers Time Extensions

CFTC Allows Swap Dealer’s CCO to Report to the Governing Body

On November 25, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter permitting the chief compliance officer (CCO) of a provisionally registered...more

1/15/2015 - C-Suite Executives CFTC Chief Compliance Officers Corporate Officers Directors DSIO No-Action Relief Reporting Requirements Swap Dealers

CFTC Staff Issues Guidance Regarding Chief Compliance Officer Annual Reports

On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued guidance regarding the annual reports that must be filed by the chief compliance officer (CCO)...more

1/14/2015 - Annual Reports CFTC Chief Compliance Officers DSIO FCMs Major Swap Participants Swap Dealers

CME Strikes Revisions to Wash Trade Advisory Notice Regarding Block Trades

On January 6, the CME Group Exchanges (CME Group) issued an amended Advisory Notice on wash trades, which removes language prohibiting block trades between accounts with the same beneficial ownership. As reported in the...more

1/14/2015 - Amended Regulation Block Trades CME Wash Trades

CFTC Staff Extends No-Action Relief for Certain FCMs from Receipt of Depository Acknowledgment Letters

On December 29, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) granted an extension of previous no-action relief for certain futures commission merchants (FCMs) to...more

1/14/2015 - CFTC DSIO FCMs No-Action Relief

ICE Futures U.S. Adopts Disruptive Trading Practices Rule

On December 29, 2014, ICE Futures U.S. (ICE) proposed a new rule to prohibit certain disruptive trading practices. The proposed rule broadly prohibits any manipulative or disruptive trading practice as defined by the...more

1/14/2015 - CFTC Commodities Exchange Act Disruptive Trading Practices Proposed Regulation

CFTC Staff Grants No-Action Relief to Entities Operating Insurance-Linked Securities Issuers

On December 18, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a letter granting relief from commodity pool operator (CPO) registration to certain entities...more

1/14/2015 - CFTC CPOs DSIO Insurance-based Securities No-Action Relief Registration

CME Issues Revisions to Wash Trade Advisory Notice

On December 17, the CME Group Exchanges (CME Group) issued Market Regulation Advisory Notice RA1411-5 to provide updated guidance on wash trades. The Advisory Notice revises portions of the frequently asked questions section...more

12/29/2014 - CME Guidance Update Wash Trades

CFTC Extends Relief from Certain Recordkeeping Requirements

The Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight (Divisions) of the Commodity Futures Trading Commission expanded and extended the no-action relief previously granted to commodity...more

12/24/2014 - CFTC DSIO No-Action Relief Recordkeeping Requirements SEFs Swaps

CFTC Approves Amended Order of Registration for LCH.Clearnet Ltd.

On December 17, the Commodity Futures Trading Commission approved the application of LCH.Clearnet Ltd. for an Amended Order of Registration as a derivatives clearing organization (DCO). Pursuant to the Amended Order, LCH is...more

12/24/2014 - CFTC Derivatives Clearing Organizations No-Action Relief

NFA Proposes Amended Interpretive Notice Regarding Loans to CPOs by Commodity Pools

On December 12, National Futures Association (NFA) submitted to the Commodity Futures Trading Commission proposed amendments to the Interpretive Notice to NFA Compliance Rule 2-45 (Prohibition of Loans by Commodity Pools to...more

12/24/2014 - CFTC Commodity Pool CPOs Loans NFA Proposed Amendments

CFTC Extends Relief to Four Foreign Clearing Organizations

On December 18, the Division of Clearing and Risk (DCR) of the Commodity Futures Trading Commission extended the no-action relief previously granted to four foreign clearing organizations: ASX Clear (Futures) Pty Limited,...more

12/24/2014 - CFTC Clearing Agencies Foreign Entities No-Action Relief

NFA Issues Guidance on Exempt and Excluded CPOs and CTAs

On December 3, National Futures Association (NFA) issued guidance reminding firms that are relying on certain exemptions or exclusions from registration as commodity pool operators (CPOs) or commodity trading advisors (CTAs)...more

12/10/2014 - CPOs CTA Exemptions National Futures Association New Guidance Registration

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