Stephen Vine

Stephen Vine

Akin Gump Strauss Hauer & Feld LLP

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Latest Posts › CFTC


CFTC Proposes Amendments to Position Limit Aggregation Exemption Rules

On September 22, 2015, the Commodity Futures Trading Commission (CFTC) proposed certain changes in a supplemental notice of proposed rulemaking (the “Supplemental Notice”) to the position limit aggregation rules and...more

9/24/2015 - Aggregation Rules CFTC Comment Period Exemptions NPRM Proposed Amendments

CFTC Staff Allows Self Executing Delegation of CPO Functions

The staff of the Commodity Futures Trading Commission (CFTC) yesterday changed its position and no longer requires a no-action request for delegation of commodity pool operator (CPO) functions from persons that might...more

10/17/2014 - CFTC CPOs Delegation Clauses No-Action Relief Registration

CFTC Publishes Long-Awaited JOBS Act Relief

The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more

9/12/2014 - CFTC CPO Disclosure Requirements Exemptions General Solicitation JOBS Act No-Action Letters Private Offerings Reporting Requirements Rule Rule 144A Rule 506(c) SEC

CFTC Staff Announces Streamlined Process for CPO Delegation

On March 12, 2014, the Commodity Futures Trading Commission (CFTC) staff issued the long-awaited guidance letter relating to the delegation of commodity pool operator (CPO) functions from persons that might otherwise be...more

5/15/2014 - CFTC CPO No-Action Letters No-Action Relief

CFTC Re-Proposes Position Limits for Certain Commodity Futures Contracts and Economically Equivalent Swaps

On November 5, 2013, the Commodity Futures Trading Commission (CFTC) re-proposed speculative position limits relating to certain U.S. exchange-listed physical commodity futures contracts as well as to swaps that reference the...more

12/24/2013 - CFTC Commodity Futures Contracts Swap Dealers Swaps

Non-U.S. Managers’ Offshore Pools Must Be Looked Through for U.S. Swaps Regulation

Swaps market participants that are not “U.S. persons” may not be subject to the full requirements of the Commodity Futures Trading Commission’s (CFTC) swaps regulation, depending on with whom they enter into a swap. Also,...more

8/22/2013 - CFTC Commodity Pool Major Swap Participants Offshore Funds Swap Dealers Swaps

CFTC Amends Certain Record Retention and Document Distribution Requirements for All CPOs and CTAs

On August 13, 2013, the Commodity Futures Trading Commission (CFTC) adopted amendments to certain provisions of Part 4 of the CFTC regulations that are applicable to all commodity pool operators (CPOs) and commodity trading...more

8/21/2013 - CFTC Commodity Pool CPO CTA Disclosure Requirements Distribution Rules Documentation Investment Company Act of 1940 Recordkeeping Requirements RICs SEC

Swaps Based on Foreign Securities May Soon Count Toward De Minimis Calculations

In their joint swap definitions release in July 2012, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) made a distinction between (i) a “compo” equity total return swap, in...more

6/25/2013 - CFTC De Minimis Claims Dodd-Frank Foreign Currency SEC Swaps

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