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P. Georgia Bullitt

P. Georgia Bullitt

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

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