Richard B. Stephens

Richard B. Stephens

Holland & Knight LLP

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Latest Publications


Guarantees of Interest Rate Swap Obligations by Non-ECP Guarantors Are Probably Illegal and Unenforceable

Options for Lenders to Consider Until the CFTC Offers Further Guidance - The Commodity Futures Trading Commission (the CFTC) has made a determination that could affect the legality and enforceability of certain...more


Dodd-Frank Rules Clarify Relief from Swap Regulation for Certain Energy, Emission and Other Commodity Swaps

As a general matter, commodity swaps and options on commodities, whether or not physically settled, are subject to regulation under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank"). This is because...more

9/5/2012 - CEA CFTC Dodd-Frank Forward Contract Exclusion Swap Agreements Swaps

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