W. Graham McCall

W. Graham McCall

Skadden, Arps, Slate, Meagher & Flom LLP

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"Prudential Regulators Extend Swaps Clearing Exemptions and Exceptions to Non-Cleared Swap Margin Requirements"

On August 2, 2016, federal banking regulators (Prudential Regulators) adopted a final rule (PR Margin Exemptions) implementing exemptions from the Prudential Regulators’ impending initial and variation margin requirements for...more

8/10/2016 - Banking Regulators CFTC Dodd-Frank Margin Requirements Non-Cleared Swaps SEC Security-Based Swaps Swap Dealers

"Recent Bills to Amend Dodd-Frank Preview Coming Attractions in Post-Election Congress"

Recently introduced legislation suggests that Republicans and Democrats in post-election Congress will be looking in very different directions on how to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act...more

7/29/2016 - Basel III Civil Monetary Penalty Commodities Exchange Act Cross-Border Derivatives Dodd-Frank FDIC Financial Institutions FSOC FX Forwards Political Parties Presidential Elections Proposed Amendments SEC Swaps

CFTC Proposes to Apply Clearing Requirement to Additional Interest Rate Swaps

On June 9, 2016, the Commodity Futures Trading Commission (CFTC) proposed to require additional interest rate swaps to be centrally cleared. Since December 2012, the CFTC has required four classes of interest rate swaps...more

6/17/2016 - CFTC Commercial End-User Exception Derivatives Derivatives Clearing Organizations Interest Rate Swaps Mandatory Clearing Requirements Swaps

CFTC Finalizes Cross-Border Margin Rules for Uncleared Swaps

On May 24, 2016, the Commodity Futures Trading Commission (CFTC) adopted final rules (cross-border margin rules) that specify how its recently issued uncleared margin rules apply to cross-border transactions. Chairman Timothy...more

6/6/2016 - CFTC Cross-Border Dodd-Frank Final Rules Major Swap Participants Margin Requirements Swap Dealers Swaps Uncleared Swaps

"CFTC Proposes Exclusion of Certain Electric Power and Natural Gas Contracts From 'Swap' Definition"

On April 4, 2016, the Commodity Futures Trading Commission (CFTC) proposed guidance that would exclude certain capacity contracts in electric power markets (capacity contracts) and natural gas peaking supply contracts from...more

4/11/2016 - Capacity Market CEA CFTC Electric Generation Suppliers Electricity Natural Gas Supply Contracts Swaps

"CFTC Eliminates End-User Trade Option Reporting Requirements and Addresses Applicability of Position Limits"

The Commodity Futures Trading Commission (CFTC or Commission) adopted a final rule effective March 21, 2016, that eliminates the reporting and recordkeeping requirements under the CFTC’s existing trade option exemption for...more

3/28/2016 - CFTC Derivatives End-Users Major Swap Participants Position Limits Reporting Requirements Swap Dealers

"CFTC Staff Provides Foreign Intermediary Registration Relief for Foreign Customers' Uncleared Swaps"

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (CFTC) has issued no-action relief from the requirement to register as an introducing broker (IB), commodity trading advisor...more

2/17/2016 - CFTC Commodity Broker Commodity Pool Introducing Brokers No-Action Relief Registration Requirement Uncleared Swaps

"Prudential Regulators Finalize Margin Requirements for Non-Cleared Swaps"

Federal banking regulators (Prudential Regulators) have finalized much-anticipated rules (Final Rules) relating to initial and variation margin requirements for certain swaps and security-based swaps that are not centrally...more

11/3/2015 - Affiliates CFTC Commercial End-User Exception Compliance Dates Covered Swap Entities (CSE) Cross-Border Customer Collateral Requirements Derivatives Final Rules Investment Management Margin Requirements Non-Cleared Swaps Prudential Regulation Authority SEC Security-Based Swaps Swaps

"CFTC Extends Registered Futures Association Membership Requirement to Introducing Brokers, Commodity Pool Operators and Commodity...

The Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule (“Final Rule”) that formally extends the existing registered futures association (“RFA”) membership requirement to registered introducing...more

9/14/2015 - Brokers CFTC Commodity Pool CPOs CTA Derivatives Final Rules Investment Adviser Major Swap Participants National Futures Association NFA Registered Futures Association Membership Registration Requirement Swap Dealers Swaps

"CFTC Proposes Rules for Cross-Border Application of Uncleared Margin"

The Commodity Futures Trading Commission (CFTC) recently proposed rules1 to address the cross-border application of margin requirements for uncleared swaps for swap dealers and major swap participants not subject to...more

7/15/2015 - CFTC Commodities Cross-Border Derivatives Margin Requirements Non-US Entities Prudential Regulation Authority SEC Swaps

"CFTC Issues Revised Embedded Volumetric Optionality Interpretation for Swaps"

On May 12, 2015, the Commodity Futures Trading Commission (CFTC) issued revised interpretive guidance for forward contracts with embedded volumetric optionality (EVO). In 2012, the CFTC and Securities and Exchange Commission...more

5/19/2015 - CFTC Forward Contracts Guidance Update Interpretive Opinions Major Swap Participants SEC Swap Dealers Swaps

"CFTC Proposes to Reduce Trade Option Reporting Requirements for Commercial End-Users"

Trade options are physically settled over-the-counter options on most deliverable commodities (e.g., agricultural, energy, or metals) where the buyer is a producer, processor, commercial user or merchant of the commodity...more

5/4/2015 - CFTC DMO End-Users Reporting Requirements Swap Data Repositories Swaps Trade Options

"SEC Proposes How to Apply Security-Based Swap Rules to Non-US Persons When Using US Personnel"

On April 29, 2015, the Securities and Exchange Commission (SEC) proposed new rules1 that would address how registration, SEC Regulation SBSR and other SEC requirements for security-based swap transactions would apply to a...more

5/4/2015 - CFTC Non-US Entities SEC Security-Based Swaps Swaps

"CFTC Extends Annual Report Deadline for Certain Chief Compliance Officers"

Last week, the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief that provides chief compliance officers (CCOs) of registered swap dealers (SDs),...more

3/31/2015 - Annual Reports CFTC Chief Compliance Officers DSIO Filing Deadlines Future Commission Merchants Major Swap Participants Swap Dealers Swaps

"CFTC Fine-Tunes Rules, Emphasizing Relief for Commercial End-Users"

On November 3, 2014, the Commodity Futures Trading Commission (CFTC or Commission) approved three proposals that Chairman Timothy Massad described as “fine tuning” certain of the CFTC’s rules “to make sure they do not impose...more

11/18/2014 - CFTC DCMs Derivatives No-Action Relief Reporting Requirements Risk Mitigation SEFs

"CFTC Further Extends Comment Periods on Position Limits Proposals"

The Commodity Futures Trading Commission (Commission or CFTC) has further extended the comment periods for its November 2013 proposal concerning position limits aggregation and its December 2013 proposal concerning position...more

7/7/2014 - CFTC Commodities Derivatives Rulemaking Process

"SEC Begins to Finalize Cross-Border Security-Based Swaps Rules"

On June 25, 2014, the Securities and Exchange Commission (SEC) adopted the first of a series of rules and guidance that will establish how security-based (SB) swap requirements under the Dodd-Frank Wall Street Reform and...more

6/26/2014 - Cross-Border Dodd-Frank SEC Security-Based Swaps

SEC Proposes Securities-Based Swap Recordkeeping, Reporting and Notification Requirements

On May 2, 2014, the Securities and Exchange Commission (SEC)published in the Federal Register proposed regulations1 that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street...more

6/6/2014 - Broker-Dealer Dodd-Frank Major Swap Participants Notice Requirements Proposed Regulation Recordkeeping Requirements Reporting Requirements SEC Security-Based Swaps Swaps

"CFTC Proposes Three Actions to Address Rulemaking Issues"

On May 22, 2014, the Commodity Futures Trading Commission (Commission or CFTC) and its staff took three actions. First, the Commission proposed to amend its existing definition of “swap dealer” in order to allow...more

5/30/2014 - CFTC Commodities Derivatives Swap Dealers Swaps

"SEC Proposes Security-Based Swap Recordkeeping, Reporting and Notification Requirements and Capital Rules for SEC Registrants"

On April 17, 2014, the Securities and Exchange Commission (SEC) proposed new regulations that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street Reform and Consumer...more

4/18/2014 - Capital Requirements Dodd-Frank Notice Requirements Recordkeeping Requirements Reporting Requirements SEC Swaps

"CFTC Deadlines Approach for Swap Dealer Margin Segregation Notifications and Buy-Side Responses"

Market participants that enter into uncleared swaps should expect to receive notifications from swap dealer (SD) and major swap participant (MSP) counterparties regarding segregation of initial margin for swaps. Dodd-Frank...more

4/3/2014 - CFTC Commodities Exchange Act Dodd-Frank Segregation Requirements Swap Dealers Swaps

"Mandatory SEF/DCM Trading Begins for Certain Interest Rate Swaps"

As of February 15, 2014, certain types of fixed-for-floating interest rate swaps must be executed on a swap execution facility (SEF) or a designated contract market (DCM), unless an exception applies (e.g., the commercial...more

2/18/2014 - CFTC Credit Default Swaps Interest Rate Swaps MTFs SEFs Swaps

CFTC Re-Proposes Speculative Position Limit Rules For Futures, Options And Swaps On Physical Commodities

On November 5, 2013, the Commodity Futures Trading Commission (CFTC) voted 3-1 to re-propose rules to establish speculative position limits for futures, options and economically equivalent swaps on certain agricultural, metal...more

12/26/2013 - Bona Fide Hedging CFTC Commodities Futures Hedging Swaps Trade Options

"CFTC Expands Large Trader Reporting and Increases Customer Account Protection Requirements"

The Commodity Futures Trading Commission (CFTC or Commission) recently adopted several rules to improve large trader reporting, facilitate segregation of customer swap margin and enhance customer protections for futures and...more

11/13/2013 - CFTC Commodities Exchange Act Customer Funds Protection Derivatives Clearing Organizations Dodd-Frank FCMs Major Swap Participants Mandatory Clearing Requirements Margin Requirements Reporting Requirements Segregation Requirements Swap Dealers Swaps

"CFTC Deadlines Loom for Commercial End Users"

End users of swaps should be aware of three impending deadlines for complying with new Commodity Futures Trading Commission (CFTC) regulations....more

8/12/2013 - CDS CEA CFTC Commercial End-User Exception Deadlines End-Users IRS Reporting Requirements

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