On May 18, 2015, the Commodity Futures Trading Commission (“CFTC”) published a final interpretation on forward contracts with embedded volumetric optionality (“Final EVO Interpretation”).1 In the Final EVO...more
As 2015 is now underway, we wanted to highlight some of the potential regulatory developments from the CFTC that may arise in the new year.
Overall we expect 2015 to be a year of continued CFTC implementation of the...more
The Commodity Futures Trading Commission (“CFTC”) recently ordered Summit Energy Services, Inc. (“Summit Energy”) to pay a $140,000 civil penalty to resolve allegations that it violated the Commodity Exchange Act (“CEA”). In...more
On July 23, the CFTC staff issued No-Action Letter 14-95 extending the compliance date from August 15, 2014 to February 11, 2016 for use of new Forms 40/40S—reports solicited from market participants by “special call” of the...more
Last week, Commodity Futures Trading Commission (CFTC) Commissioner Scott O'Malia, sharply criticized a potentially significant expansion of the CFTC Enforcement Division’s investigatory powers. In an unusual "dissenting...more