CFTC Re-Proposed Rules Prohibiting Aggregation of Swap Contract Orders

On June 25, the CFTC re-proposed rules prohibiting the aggregation of orders to satisfy minimum block sizes or cap requirements with respect trades in swap contracts. In addition, the proposed rules (i) provide that parties to a block trade must individually qualify as eligible contract participants, subject to certain exceptions and (ii) require that persons transacting block trades on behalf of customers must receive prior written instructions or consent from such customers. Comments must be submitted within 30 days of publication in the Federal Register. CFTC Release.

Written by:

Published In:

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Orrick, Herrington & Sutcliffe LLP | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.