Kevin M. Foley

Kevin M. Foley

Katten Muchin Rosenman LLP

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CFTC Reissues FAQ on Commodity Options

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has reissued a document addressing frequently asked questions (FAQs) on commodity options. The FAQs document, which DMO originally issued on...more

3/11/2014 - CFTC Commodities Major Swap Participants Swap Dealers Swaps Trade Options

NFA Reminds SDs and MSPs of Portfolio Reconciliation Requirements

Pursuant to Commodity Futures Trading Commission No-Action Letter No. 13-40, swap dealers (SDs) and major swap participants (MSPs) are required to comply with the portfolio reconciliation requirements in CFTC Regulation...more

8/21/2013 - CFTC Major Swap Participants NFA Portfolio Reconciliation Swap Dealers Swaps

Mandatory Clearing of iTraxx CDS Indices for Category 2 Entities Began July 25

The Division of Clearing and Risk of the Commodity Futures Trading Commission announced that commodity pools, private funds (other than active funds) and certain other persons predominantly engaged in banking or financial...more

7/30/2013 - CFTC Commodity Pool iTraxx CDS indices Major Swap Participants Private Funds Swap Dealers Swaps

Portfolio Reconciliation and Swap Trading Relationship Documentation Requirements for SDs and MSPs

Provisionally registered swap dealers (SDs) and major swap participants (MSPs) are required by the National Futures Association (NFA) to submit portfolio reconciliation and swap trading relationship documentation policies and...more

7/2/2013 - CFTC Compliance Investment Portfolios Major Swap Participants NFA Required Documentation Swap Dealers Swaps

CFTC Issues No-Action Letters

The Commodity Futures Trading Commission 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 portfolio...more

7/2/2013 - CFTC Chief Compliance Officers Dodd-Frank Major Swap Participants Swap Dealers Wall Street

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

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 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

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