Stephen M. Quinlivan

Stephen M. Quinlivan

Stinson Leonard Street

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CFTC Provides No-Action Relief For Treasury Subsidiaries And Affiliates

Broc Romanek of TheCorporateCounsel.net recently described a member’s concerns that some companies were having on relying on the Dodd-Frank Act’s exemption for end-users for swaps entered into by treasury subsidiaries and...more

6/5/2013 - Affiliates CFTC Dodd-Frank End-Users No-Action Relief Subsidiaries Swaps

ECP Guarantor Provisions In Corporate Credit Agreements

Many corporate credit agreements are supported by subsidiary guarantees. Those guarantees often include not only the guaranty of the obligations under the credit agreement but also any related swap agreements. The CFTC has...more

4/30/2013 - CFTC Credit Agreements Eligible Contract Participant Guarantors Swap Agreements Swaps

ISDA: Be Ready For May 1 And Standard Swap Confirmation

By May 1, all counterparties must have provided their registered swap dealers with legal classifications and representations to allow the swap dealers to comply with the CFTC’s External Business Conduct Rule (EBCR). After the...more

4/24/2013 - CFTC Deadlines ISDA Swap Dealers Swaps

CFTC Commissioners Bicker About Budget And Performance Report

There continues to be significant public discord amongst the Commissioners at the CFTC. According to Commissioner Scott O’Malia “Given the vast deficit spending challenges this country is facing, I do not believe it is...more

4/15/2013 - CFTC Dodd-Frank Federal Budget Spending Cuts

CFTC Approves Final Regulations Governing Exemption From Required Clearing For Inter-Affiliate Swaps

The CFTC has issued a final rule to exempt swaps between certain affiliated entities within a corporate group from the clearing requirement under the Commodity Exchange Act, or CEA, and CFTC regulations. ...more

4/2/2013 - CFTC Commodities Exchange Act Mandatory Clearing Requirements Reporting Requirements Swap Data Repositories Swaps

CFTC Provides Relief For Partial Swap Terminations

The CFTC’s Division of Clearing and Risk has issued a no-action letter that provides relief from required clearing for a limited set of “stub swaps” that remain after the partial novation or partial termination of an original...more

3/25/2013 - CFTC Mandatory Clearing Requirements No-Action Relief Novation Stub Swaps Swaps Termination

CFTC Reminds All Swap Counterparties Of April 10 Deadline To Obtain A CICI Identifier

The Division of Market Oversight, or DMO, and Office of Data and Technology, or ODT of the CFTC have issued an advisory reminding all swap counterparties of the imminent April 10, 2013, deadline for each counterparty to...more

3/21/2013 - CFTC CICIs DMO Dodd-Frank ODT Swaps

CFTC’s Initial Attempts At Data Collection Fail

Since the beginning of 2013, the CFTC has required certain market participants to report their interest rate and credit index swap trades to a swap data repository, or SDR. CFTC Commissioner Scott D. O’Malia recently...more

3/21/2013 - CFTC Data Collection Recordkeeping Requirements Reporting Requirements Swaps

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