Patricia Dondanville

Patricia Dondanville

Reed Smith

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CFTC Revises Seven-Part Test for Forward Contracts with Embedded Volumetric Optionality

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

5/26/2015 - CFTC Commodities Exchange Act Dodd-Frank Forward Contracts Major Swap Participants Swap Dealers Swaps

2015 CFTC Regulatory Agenda

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

1/29/2015 - Block Trades CFTC Mandatory Clearing Requirements Regulatory Agenda Swaps

CFTC Penalizes Energy Company for Failing to Register as a CTA

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

1/23/2015 - CFTC Civil Monetary Penalty Commodities Exchange Act CTA Natural Gas Oil & Gas OTC Registration Swaps

CFTC No-Action Relief from Potentially Burdensome Requirement for Automated Form 40S Response to CFTC ‘Special Calls’

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

7/29/2014 - CFTC Form 40S Market Participants No-Action Letters No-Action Relief Special Calls Swap Dealers Swaps

CFTC Takes an Aggressive Enforcement Tack – Commissioner Criticizes Omnibus Order of Investigation (Including Subpoenas) Approved...

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

8/23/2013 - CFTC Enforcement Investigations Subpoenas

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