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"CFTC Deadlines Approach for Swap Dealer Margin Segregation Notifications and Buy-Side Responses"

Market participants that enter into uncleared swaps should expect to receive notifications from swap dealer (SD) and major swap participant (MSP) counterparties regarding segregation of initial margin for swaps. Dodd-Frank...more

4/3/2014 - CFTC Commodities Exchange Act Dodd-Frank Segregation Requirements Swap Dealers Swaps

"Mandatory SEF/DCM Trading Begins for Certain Interest Rate Swaps"

As of February 15, 2014, certain types of fixed-for-floating interest rate swaps must be executed on a swap execution facility (SEF) or a designated contract market (DCM), unless an exception applies (e.g., the commercial...more

2/18/2014 - CFTC Credit Default Swaps Interest Rate Swaps MTFs SEFs Swaps

"US Swap Regulation: Cross-Border Debate Among Issues to Watch in 2014"

Since the enactment of Dodd-Frank in 2010, the CFTC and the SEC have proceeded at different speeds to address previously unregulated markets for swaps and security-based swaps, respectively. The CFTC moved quickly to develop...more

1/28/2014 - CFTC Cross-Border Dodd-Frank EU SEC Swaps

"CFTC’s Mandatory Exchange Trading For Certain Interest Rate Swaps Starts February 15, 2014"

On January 16, 2014, staff of the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (Division) announced that the first “made-available-to-trade” determination (MAT Determination) will become...more

1/21/2014 - CFTC Designated Contract Market Swap Execution Facilities Swaps

CFTC Grants Substituted Swaps Compliance for Six Foreign Jurisdictions

In 2013, the Commodity Futures Trading Commission (CFTC) adopted final guidance describing the circumstances in which the Dodd-Frank Act requirements will apply to cross-border swap activities (Guidance). In conjunction with...more

1/13/2014 - CFTC Compliance Dodd-Frank Exemptive Orders Foreign Jurisdictions Swaps

CFTC Re-Proposes Speculative Position Limit Rules For Futures, Options And Swaps On Physical Commodities

On November 5, 2013, the Commodity Futures Trading Commission (CFTC) voted 3-1 to re-propose rules to establish speculative position limits for futures, options and economically equivalent swaps on certain agricultural, metal...more

12/26/2013 - Bona Fide Hedging CFTC Commodities Futures Hedging Swaps Trade Options

"Expiration of CFTC Cross-Border Exemption May Impact Non-US Swap Trading"

Earlier this year, the Commodity Futures Trading Commission (CFTC) issued Cross-Border Guidance that set out the agency’s interpretation on the extent to which CFTC swap regulations would apply outside the U.S. The...more

12/19/2013 - CFTC Compliance Cross-Border Exemptions Swaps

"CFTC Expands Large Trader Reporting and Increases Customer Account Protection Requirements"

The Commodity Futures Trading Commission (CFTC or Commission) recently adopted several rules to improve large trader reporting, facilitate segregation of customer swap margin and enhance customer protections for futures and...more

11/13/2013 - CFTC Commodities Exchange Act Customer Funds Protection Derivatives Clearing Organizations Dodd-Frank FCMs Major Swap Participants Mandatory Clearing Requirements Margin Requirements Reporting Requirements Segregation Requirements Swap Dealers Swaps

"CFTC Publishes Sweeping Concept Release Asking Questions About Additional Regulation of Automated Trading Strategies and...

On September 12, 2013, the Commodity Futures Trading Commission (CFTC) published a concept release (Concept Release or Release) requesting information about current market practices relating to the use of automated trading...more

10/14/2013 - ATS CFTC CPO CTA FCMs High Frequency Trading Major Swap Participants SEFs Swap Dealers Swaps

CFTC Issues Final Guidance and Accompanying Exemptive Order on Cross-Border Application of Certain Swap Regulations

At a public meeting on July 12, 2013, the Commodity Futures Trading Commission (CFTC or Commission) adopted final guidance on how Dodd-Frank Act requirements will apply to cross-border swap activities (Guidance). In...more

7/31/2013 - CFTC Compliance Cross-Border Cross-Border Transactions Dodd-Frank Exemptive Orders Major Swap Participants Swap Dealers 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 GAAP IFRS No-Action Letters No-Action Relief Reporting Requirements Subsidiaries Swaps

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

"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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