Mark D. Young

Mark D. Young

Skadden, Arps, Slate, Meagher & Flom LLP


Latest Publications

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SEC Proposes Cross-Border Security-Based Swap Rules and Guidance

On May 23, 2013, the Securities and Exchange Commission (SEC) published in the Federal Register proposed rules and guidance for applying Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank)...more

5/25/2013 - CFTC Cross-Border Transactions Dodd-Frank SEC Security-Based Swaps

"CFTC Delays April 10 Compliance Date for Many Swap Data Reporting Requirements"

On April 9, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight, responding to requests from multiple interested parties, issued a no-action letter (the No-Action Letter) extending the April...more

4/11/2013 - CFTC Dodd-Frank End-Users Legal Entity Identifiers Major Swap Participants No-Action Letters Reporting Requirements Swap Dealers Swaps

"CFTC Issues No-Action Relief From Certain Inter-Affiliate Swap Reporting Requirements"

On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk provided no-action relief (the No-Action Letter) from certain reporting requirements relating...more

4/10/2013 - CFTC No-Action Letters No-Action Relief Reporting Requirements Subsidiaries Swaps

"CFTC No-Action Letter Relieves End-Users of Part 45 Reporting for Trade Options"

On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) provided end-users no-action relief (the No-Action Letter) from certain “trade option” reporting and recordkeeping...more

4/8/2013 - CFTC End-Users Exemptions No-Action Letters Recordkeeping Requirements Trade Options

Impending Swap Reporting Requirements to Impact All Swap Market Participants

All swap market participants, including commercial end-users, should be aware of the upcoming April 10 deadline for Commodity Futures Trading Commission (CFTC) swap reporting and recordkeeping requirements under Parts 43, 45...more

4/5/2013 - CEA CFTC Dodd-Frank Reporting Requirements Swap Data Repositories Swap Market Swaps

"New CFTC Swap Clearing Rules to Require Board Review and Approval of the Election to Rely on the 'Commercial End-User Exception'"

New Commodity Futures Trading Commission (CFTC) swaps clearing rules will force non-financial entities to stop uncleared trading of certain interest-rate swaps (IRS) and index credit default swaps (index CDS) starting on...more

3/14/2013 - CFTC Commercial End-User Exception Credit Default Swaps Derivatives Clearing Organizations Dodd-Frank Interest Rate Swaps Mandatory Clearing Requirements Swaps

"Department of Labor Paves the Way to Clearing Swaps for ERISA Plans"

The Department of Labor (DOL) recently issued a long-awaited advisory opinion (the Advisory Opinion) clarifying and confirming the ability of central counterparties (CCPs) and their clearing members (Clearing Members) to...more

2/21/2013 - CCPs Clearing Members Dodd-Frank DOL ERISA Pensions Swap Clearing Swaps

"CFTC Issues Final Exemptive Order on Cross-Border Application of Certain Swap Regulations"

Swaps trade in a global market. Title VII of the Dodd-Frank Act amended the Commodity Exchange Act (CEA) to impose a panoply of regulation on the swaps market mostly through regulations adopted by the Commodity Futures...more

1/12/2013 - CEA Compliance Cross-Border Transactions Dodd-Frank Interstate Commerce Major Swap Participants Swap Dealers Swaps U.S. Person

"ISDA Dodd-Frank Protocol Update: CFTC Delays Compliance"

The Commodity Futures Trading Commission (CFTC) has issued an interim rule to extend the compliance date with certain business conduct standards (BCS) and documentation rules for swap dealers and major swap participants. The...more

12/20/2012 - CFTC Compliance DF-Protocol Dodd-Frank ISDA Swap Dealers Swaps

"CFTC Staff Provides Funds-of-Funds With Temporary No-Action Relief From Commodity Pool Operator Registration"

On November 29, 2012, the Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) issued temporary no-action relief from commodity pool operator (CPO) registration to...more

12/11/2012 - CFTC Commodity Pool No-Action Relief Swap Dealers

"CFTC Staff Provides Family Offices With No-Action Relief From Commodity Pool Operator Registration"

On November 29, 2012, the Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) issued no-action relief from commodity pool operator (CPO) registration to family offices...more

12/5/2012 - CFTC Commodity Pool Family Offices No-Action Relief Swap Dealers

"ISDA Dodd-Frank Protocol Update: ISDA Requests the CFTC to Delay Compliance With Business Conduct Standards Rules"

The Commodity Futures Trading Commission’s (CFTC) external business conduct standards (BCS) for swaps require compliance for registered swap dealers by January 1, 2013. To facilitate compliance with the BCS rules, the...more

12/3/2012 - CFTC ISDA Swaps

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