M. Holland West

M. Holland West

Dechert LLP

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CFTC Adopts New CPO Rules for Registered Investment Companies and Others

Introduction - The U.S. Commodity Futures Trading Commission (“CFTC”) recently released its long-awaited “Final Rule” to harmonize CFTC disclosure, reporting, and recordkeeping requirements with parallel U.S....more

10/7/2013 - CFTC Commodity Pool CPO International Harmonization Investment Company Act of 1940 Investment Corporations

CFTC Extends Certain SEF Reporting, Confirmation, and Documentation Compliance Dates

commoThe Division of Market Oversight (“Division”) of the U.S. Commodity Futures Trading Commission (“CFTC”) on September 27 and 30, 2013 issued several no-action letters to temporarily registered swap execution facilities...more

10/7/2013 - Asset Class CFTC Commodities Exchange Act Compliance Confirmation Proceedings Documentation Reporting Requirements SEFs Swaps

New NFA Quarterly Filing Requirements for all Registered CTAs: Action Required

The U.S. National Futures Association (NFA) has announced its eagerly anticipated new quarterly filing requirement for commodity trading advisors (CTAs). Such requirement will begin with the reporting of third quarter 2013...more

9/18/2013 - CFTC CTA Filing Requirements NFA Registration

CFTC Issues Guidance on Block Trade and Large Notional Off-Facility Swap Rules; Advisers Must Obtain Consents

The U.S. Commodity Futures Trading Commission (“CFTC”) has issued final rules (“Final Rules”) setting minimum block trade sizes for different types of CFTC regulated swaps that are permitted to be executed off-facility and...more

9/10/2013 - Block Trades CFTC Disclosure Requirements Dodd-Frank Final Rules Investment Adviser Swap Dealers Swaps

CFTC Issues Cross-Border Swaps Regulation Guidance and Exemptive Order

The U.S. Commodity Futures Trading Commission (“CFTC”) recently approved and issued its eagerly anticipated: i. final interpretive guidance and policy statement on the cross-border application of the swap regulation...more

8/7/2013 - CFTC Commodities Exchange Act Cross-Border Cross-Border Transactions Exemptive Orders Swaps

401(k) Plans—Potential Commodity Pool Issues in the United States

Under the rules of the Commodity Futures Trading Commission (“CFTC”), certain collective investment vehicles and other entities that, directly or indirectly, invest in “commodity interests” may be “commodity pools” whose...more

2/28/2013 - 401k CFTC Commodity Pool CPO NFA Participant-Directed Plans Retirement Plan

CFTC Issues Broad Securitization Industry Relief on Commodity Pool Regulation

On Friday, December 7, 2012, the U.S. Commodity Futures Trading Commission (CFTC), through its Division of Swap Dealer and Intermediary Oversight (Division), issued a letter which provides broad relief for certain segments of...more

12/13/2012 - CFTC Commodity Pool No-Action Relief Securitization Vehicles Swap Dealers

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