Kevin M. Foley

Kevin M. Foley

Katten Muchin Rosenman LLP

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Extension of Time-Limited, Conditional No-Action Relief Regarding Masking Certain Reportable Identifying Information

On January 15, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) issued CFTC letter 16-03 (“Letter”) providing a conditional, time-limited extension of the relief provided in CFTC Letter 13-41,...more

1/27/2016 - CFTC Data Privacy No-Action Relief Reporting Requirements Swaps

CFTC Issues No-Action Relief From the Swap Clearing Requirements for Small Bank Holding Companies, Small Savings and Loan Holding...

On January 8, the Division of Clearing and Risk (Division) of the Commodity Futures Trading Commission issued no-action relief from the swap clearing requirements of Section 2(h)(1)(A) of the Commodity Exchange Act to certain...more

1/19/2016 - Bank Holding Company CFTC Federal Savings Associations No-Action Relief Swap Clearing

CFTC Provides Relief to SEFs From Audit Trail Requirements Related to Post-Trade Allocation Information

The Division of Market Oversight of the Commodity Futures Trading Commission has issued temporary no-action relief to swap execution facilities (SEFs) from certain audit trail requirements related to post-trade allocations....more

1/13/2016 - Allocation of Funds Audit Reports CFTC No-Action Relief SEFs

CFTC Extends Continued No-Action Relief From Certain Recordkeeping Requirements

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and Division of Market Oversight (collectively, Divisions) have issued CFTC Letter No. 15-65, which indefinitely extends the...more

12/15/2015 - CFTC Commodity Broker No-Action Relief Recordkeeping Requirements Regulatory Oversight

CFTC Extends No-Action Relief to Certain Affiliated Counterparties

On November 17, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) and Division of Clearing and Risk (DCR) each extended no-action relief for certain affiliated counterparties....more

11/24/2015 - CFTC DMO No-Action Relief Regulatory Oversight Trading Platforms

CFTC Extends Time-Limited Relief to SEFs for Block Trades

The Division of Market Oversight of the Commodity Futures Trading Commission has extended no-action relief for swap execution facilities (SEFs) from certain block trade requirements. Specifically, CFTC Letter No. 15-60...more

11/11/2015 - CFTC No-Action Relief SEFs

CFTC Further Extends No-Action Relief for Certain Package Transaction Swaps

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has issued CFTC Letter No. 15-55, extending until November 15, 2016, time-limited no-action relief for certain swaps executed as part of a package...more

10/20/2015 - CFTC Commodities Exchange Act Counterparties Jurisdiction No-Action Relief SEFs Swaps

CFTC Extends Relief from Electronic OCR Requirements

The Division of Market Oversight of the Commodity Futures Trading Commission has extended no-action relief from certain of the CFTC’s ownership and control reporting (OCR) regulations, including electronic reporting via new...more

10/7/2015 - CFTC Electronic Reporting No-Action Relief OCR

CFTC Extends Relief for Non-US Swap Dealers From Transaction-Level Requirements

On August 13, the Division of Swap Dealer and Intermediary Oversight, Division of Clearing and Risk, and Division of Market Oversight of the Commodity Futures Trading Commission extended no-action relief from certain...more

8/19/2015 - CFTC Cross-Border Transactions DSIO No-Action Relief Swap Dealers Swaps

CFTC Further Extends Valuation Data Reporting Relief for SDs and MSPs

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has further extended no-action relief from the valuation data reporting requirements for cleared swaps under CFTC Regulation 45.4(b)(2)(ii)....more

6/23/2015 - CFTC Counterparties DMO Major Swap Participants No-Action Relief Reporting Requirements Swap Dealers Swaps

CFTC Issues Relief From IB and CTA Registration to Foreign Persons Dealing in Swaps for International Financial Institutions

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from introducing broker (IB) and commodity trading advisor (CTA) registration to persons...more

6/17/2015 - CFTC CTA DSIO Financial Institutions Foreign Banks Introducing Brokers No-Action Relief Swap Dealers Swaps World Bank

CFTC Issues No-Action Relief to SEFs and DCMs in Connection with Swaps with Operational or Clerical Errors

On April 22, the Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk (Divisions) issued CFTC Letter No. 15-24 to provide no-action relief to enable swap execution facilities...more

4/28/2015 - CFTC DCMs No-Action Relief SEFs

CFTC Issues No-Action Relief for SEF Confirmation and Recordkeeping Requirements and Confirmation Data Reporting Requirements

On August 14, 2014, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) granted no-action relief to swap execution facilities (SEFs) from the confirmation and recordkeeping requirements set forth in...more

4/28/2015 - CFTC No-Action Relief Recordkeeping Requirements Reporting Requirements SEFs

CFTC Extends CCO Report Filing Deadline

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued permanent no-action relief from the filing deadline for chief compliance officer (CCO) annual reports....more

4/7/2015 - CFTC Chief Compliance Officers DSIO FCMs Filing Deadlines Major Swap Participants No-Action Relief Swap Dealers

CFTC Issues Advisory on Ownership and Control Reporting

The Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission have issued an advisory on ownership and control reporting (OCR) for futures...more

4/1/2015 - Advisory Opinions CFTC DSIO FCMs Market Participants No-Action Relief Reporting Requirements Swap Dealers

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

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 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

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 No-Action Relief Registration

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

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

CFTC Extends Relief for Non-US Swap Dealers from Transaction-Level Requirements

The Division of Swap Dealer and Intermediary Oversight, Division of Clearing and Risk and the Division of Market Oversight (Divisions) of the Commodity Futures Trading Commission have extended the no-action relief previously...more

11/26/2014 - CFTC No-Action Relief Swap Dealers

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