Meghan R. Gruebner

Meghan R. Gruebner

Sutherland Asbill & Brennan LLP

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Update: FERC Five-Year Review of Oil Pipeline Rate Indexation

On June 30, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (NOI) that proposed an adjustment to the annual indexation formula for oil pipeline rates. The NOI sought comments on a proposed...more

8/5/2015 - Comment Period FERC Notice of Inquiry Oil & Gas Pipelines Technical Conference

CFTC Fines Summit Energy Services, Inc. for Violating CTA Registration Rules Under the Commodity Exchange Act

On January 16, the Commodity Futures Trading Commission (CFTC) issued a settlement order requiring Summit Energy Services, Inc. (Summit Energy) to pay a $140,000 civil monetary penalty for acting as an unregistered commodity...more

2/5/2015 - CFTC Civil Monetary Penalty Commodities Exchange Act CTA Enforcement Actions Summit Energy

CFTC Grants No-Action Relief to Commodity Pool Operators with Respect to Certain Insurance-Linked Securitization Vehicles

Toward the end of 2014, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued two letters affecting insurance-linked securitization vehicles: CFTC...more

1/19/2015 - CFTC CPOs DSIO No-Action Relief SIFMA Swap Dealers Swaps

Congress Exempts Non-Financial End-Users, Their Agents and Certain Cooperatives From Non-Cleared Swap Margin Requirements in...

On January 8, 2015, the U.S. Senate approved legislation, by a 93-4 vote, to reauthorize the Terrorism Risk Insurance Act (“TRIA”). The legislation, dubbed the Terrorism Risk Insurance Program Reauthorization Act of 2015 (the...more

1/12/2015 - CFTC Commodities Exchange Act Covered Entities Major Swap Participants Margin Requirements Pending Legislation Prudential Regulation Authority Swap Dealers Swaps Terrorism Insurance TRIA

CFTC Expands Existing Clearing Relief for Treasury Affiliates

On November 24, the Commodity Futures Trading Commission’s (CFTC) Division of Clearing and Risk (DCR) issued a no-action letter to expand previously issued relief, that is available to “treasury affiliates,” from the...more

12/24/2014 - CFTC Clearing Agencies No-Action Relief Swaps Treasury Affiliates

ESMA Issues Revision of the Technical Standards on Reporting under Article 9 of EMIR

On November 10, the European Securities and Markets Authority (ESMA) published a consultation paper relating to the Regulatory Technical Standards and Implementing Technical Standards (collectively, the Technical Standards),...more

11/25/2014 - EMIR ESMA EU Technical Standards

FERC Issues Proposed Policy Statement on Cost Recovery Mechanisms for Modernization of Natural Gas Facilities

On November 20, the Federal Energy Regulatory Commission (Commission) issued a Proposed Policy Statement on cost recovery mechanisms, such as trackers or surcharges, that pipelines may use to recoup infrastructure...more

11/24/2014 - EPA FERC Natural Gas Oil & Gas PHMSA Pipelines Power Infrastructure

CFTC Clarifies Dealer Requirement to Notify Customers of Right to Segregation of Initial Margin for Uncleared Swaps

On October 31, the Division of Swap Dealer and Intermediary Oversight (Division) of the Commodity Futures Trading Commission (CFTC) issued a staff interpretation regarding the notification of the right to segregation of...more

11/5/2014 - Broker-Dealer CFTC Major Swap Participants Reporting Requirements Segregated Funds

ESMA Issues Final Draft Standards for the Central Clearing of Certain Interest Rate Swaps under EMIR

On October 1, the European Securities and Markets Authority (ESMA) issued final draft regulatory technical standards (RTS) with respect to the central clearing of four classes of interest rate swaps (IRS). The RTS follows...more

10/16/2014 - EMIR ESMA EU Interest Rates Swaps

Regulators Publish Re-proposed Margin Requirements for Uncleared Swaps

On September 3, 2014, the Board of Governors of the Federal Reserve System (the Board) jointly adopted, with certain federal banking regulators, re-proposed rules that will require registered swap dealers, security-based swap...more

9/25/2014 - Banks Basel Committee CFTC Dodd-Frank Federal Reserve IOSCO Major Swap Participants Margin Requirements Prudential Regulation Authority SEC Swap Dealers Swap Market Swaps

Legal Alert: Crowley Marine Subsidiary Carib Energy Receives Authorization to Export LNG to Non-FTA Nations

Today, the U.S. Department of Energy (DOE) issued a final order authorizing Carib Energy (USA) LLC (Carib), a wholly-owned subsidiary of Crowley Marine, to export up to 400,000 gallons of LNG per day in ISO containers over a...more

9/11/2014 - DOE Energy Energy Policy Exports Free Trade Agreement Liquid Natural Gas

ISDA Section 2(a)(iii) Amendment Limits Prerogatives of Non-Defaulting Parties

On June 19, the International Swaps and Derivatives Association (ISDA) published a long-awaited standard amendment to Section 2(a)(iii) of the ISDA Master Agreement (the Master Agreement). Section 2(a)(iii) of the Master...more

7/23/2014 - Default Derivatives ISDA ISDA Master Agreement Swaps

Legal Alert: CFTC Division of Market Oversight Releases Questions for June 19 Roundtable on Position Limits

The Commodity Futures Trading Commission (CFTC) will host a public roundtable on June 19, 2014, to discuss questions related to a proposed rulemaking to establish speculative position limits for 28 exempt and agricultural...more

6/19/2014 - CFTC Commodity Futures Contracts Compliance Position Limits Swaps

NFA Issues Revised Forms CPO-PQR and CTA-PR

On June 5, the National Futures Association (NFA) announced the issuance of revised Forms CPO-PQR and CTA-PR. The NFA is the self-regulatory organization to which the Commodity Futures Trading Commission (CFTC) has delegated...more

6/10/2014 - CFTC CPO CTA NFA Registration

Storm Clouds Continue to Gather Over Bankruptcy Code’s Safe Harbors

As noted in a previous Sutherland Legal Alert, the American Bankruptcy Institute has formed a Commission to Study the Reform of Chapter 11 (the Commission). To further its goal of proposing changes to modernize the Bankruptcy...more

5/30/2014 - Bankruptcy Code Chapter 11 Commercial Bankruptcy Debtors-in-Possession Dodd-Frank FDIA Safe Harbors Title II

Legal Alert: CFTC Adopts Streamlined Approach for Delegation of CPO Registration

On May 12, 2014, the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued a staff letter (the Staff Letter) that provides a streamlined approach for commodity pool...more

5/20/2014 - CFTC Commodity Pool Compliance CPO DSIO

CFTC Affords Market Participants a “Second Bite” at the Swap Recordkeeping and Reporting Rules

Last month, the Commodity Futures Trading Commission (CFTC) issued a request for public comment on its swap data recordkeeping and reporting requirements under Part 45 of its regulations. The CFTC adopted Part 45 in 2012...more

4/3/2014 - CFTC Dodd-Frank Recordkeeping Requirements

FERC Issues a NOPR Reforming Gas Day and Two Orders to Improve Natural Gas – Electric Generation Industry Coordination

On March 20, 2014, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) and two separate, but related, Orders to improve the coordination of scheduling natural gas pipeline capacity to...more

3/27/2014 - Energy FERC Natural Gas Utilities Sector

NIST Cybersecurity Framework – What It Is and What It Means for the Energy Industry

The federal government’s long-awaited Cybersecurity Framework offers promising tools for energy companies to manage their cybersecurity risk, but leaves many questions unanswered. The National Institute of Standards and...more

2/17/2014 - Critical Infrastructure Sectors Cybersecurity Cybersecurity Framework Data Protection Energy NIST Utilities Sector

CFTC Certifies Two More “Available to Trade” Determinations

Last week, the Commodity Futures Trading Commission (CFTC) certified two additional available to trade determinations (MAT determinations). The latest MAT determinations cover additional interest rate swaps (IRS) and, for the...more

2/6/2014 - CFTC Credit Default Swaps Interest Rate Swaps Swaps

Commodity Pool Operators and Commodity Trading Advisors: Are Enhanced Customer Protections on the Horizon?

On January 23, 2014, the National Futures Association (NFA) issued a Request for Comments from commodity pool operators (CPOs) and commodity trading advisors (CTAs) as to whether the NFA should adopt rules to: (1) ensure that...more

1/31/2014 - CFTC Compliance CPO CTA Deadlines Financial Regulatory Reform NFA

Legal Alerts: CFTC Certifies Additional “Available to Trade” Designation: Certain Interest Rate Swaps Must Be Executed on a SEF...

On Thursday, January 23, 2014, the Commodity Futures Trading Commission (CFTC) certified a second available to trade determination (the Second MAT Determination) in response to an application submitted by trueEX, LLC. ...more

1/28/2014 - CFTC SEFs Swap Dealers Swap Execution Facilities Swaps trueEX

Update: An End-User’s Guide to the CFTC’s Final Cross-Border Guidance

There were a number of new developments with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requirements for swaps in the latter part of 2013. This...more

1/22/2014 - CFTC Cross-Border Dodd-Frank End-Users EU ISDA SIFMA Swap Dealers Swaps

CPO and CTA Annual Affirmation of Exemptions Due in March

Pursuant to Commodity Futures Trading Commission (CFTC) regulations, persons claiming an exemption or exclusion from registration as a commodity pool operator (CPO) or a commodity trading advisor (CTA), under CFTC Regulations...more

1/22/2014 - CFTC Compliance CPO CTA Exemptions

CFTC Certifies First “Available to Trade” Designation: Certain Interest Rate Swaps Must be Executed on a SEF or DCM Beginning on...

As market participants are aware, certain swaps that are subject to mandatory clearing must be executed on a registered swap execution facility (SEF) or a designated contract market (DCM) (i.e., an exchange) once a swap is...more

1/17/2014 - CFTC Securities SEFs Swaps

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