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Michael A. Piracci

Michael A. Piracci

Morgan Lewis


Latest Publications

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Federal Reserve Adopts Retail Forex Rules

Standards for banking organizations regulated by the Federal Reserve for Retail Forex are generally comparable to rules adopted by other regulators. ...more

4/25/2013 - Banking Industry Regulations Disclosure Requirements Dispute Resolution Dodd-Frank Eligible Contract Participant Federal Reserve Final Rules Forex

CFTC Adopts Tape-Recording and Recordkeeping Rules

Final rules require tape recording by futures commission merchants, introducing brokers, retail foreign exchange dealers, and commodity trading advisors; affected CFTC registrants must implement systems to comply by December...more

1/4/2013 - Broker-Dealer CFTC Commodities Compliance Foreign Exchanges Recordkeeping Requirements Tape Recordings

SEC Permits Portfolio Margining of Credit Default Swaps

Order grants exemptive relief from Exchange Act requirements; parallel CFTC relief expected soon. On December 14, the Securities and Exchange Commission (SEC) issued an order granting exemptive relief (Exemptive Order)...more

12/31/2012 - Broker-Dealer CEA CFTC Derivatives Clearing Organizations Exemptive Orders SEC Swaps

CFTC Staff No-Action Relief for Family Offices and Fund of Funds Operators

Claims for relief from CPO registration by qualifying family offices and fund of funds operators must be filed by December 31. On November 29, the Commodity Futures Trading Commission's (CFTC's) Division of Swap Dealer...more

12/6/2012 - CFTC Commodity Pool Family Offices No-Action Relief

Temporary Relief for Swap Data Reporting Requirements

CFTC issues no-action letter establishing uniform compliance dates and temporary relief for reporting of swap transaction data for swap dealers. On November 19, the Commodity Futures Trading Commission's (CFTC's)...more

11/26/2012 - CFTC DMO DSIO Swaps

Treasury Issues Final Determination on Foreign Exchange Swaps and Forwards

Foreign exchange swaps and foreign exchange forwards are exempted from the definition of "swap" under the Commodity Exchange Act. On November 16, the Secretary of the U.S. Department of the Treasury (Secretary) issued a...more

11/20/2012

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