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Many chief compliance officers struggle every year with preparing the annual review required under Advisers Act Rule 206(4)-7. To help you out, here’s our guide to writing your annual report....more
A non-US-based investment and brokerage firm agreed to settle spoofing allegations by the Commodity Futures Trading Commission by payment of a US $700,000 fine. In accepting this settlement, the CFTC emphasized the...more
The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more
Now that the sugar and the frivolity of the holiday season have worn off, let’s talk more about the different types of compliance management activities that will ensure your obligations are met, and some of the specific needs...more
The Commodity Futures Trading Commission issued revised guidance for mandatory chief compliance officer annual compliance reports for futures commission merchants and swap dealers. However, the proposed recommendations are...more
U.S. Financial Industry Developments - SEC Disapproves the Listing and Trading of Nine Bitcoin Related Exchange Traded Products - On August 22, 2018, the SEC released three Orders, acting through authority delegated to...more
On May 3, 2017, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to its rules regarding the duties of Chief Compliance Officers (“CCOs”) for swap dealers...more
Financial Industry Developments - CFTC Proposes to Amend Rules Governing Chief Compliance Officer Duties and Annual Reports for Certain Registrants - On May 3, 2017, the U.S. Commodity Futures Trading Commission...more
The CFTC is proposing to amend its regulations regarding certain duties of chief compliance officers, or CCOs, of swap dealers, major swap participants and futures commission merchants, which are referred to as registrants....more
The CFTC approved a final rule amending a CFTC regulation addressing the timing for filing chief compliance officer annual reports for certain registrants. The final rule amends CFTC regulation 3.3 to provide futures...more
On March 27, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to futures commission merchants, swap dealers and major swap participants from their obligation under...more
In This Issue: - CFTC Extends Portfolio Margining on ICE Clear Europe - CFTC Extends CCO Report Filing Deadline - CFTC Issues Relief to Swap Dealers Regarding Legacy SPV Swaps - CME Updates Order...more
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
The CFTC’s Division of Swap Dealer and Intermediary Oversight issued a no-action letter to futures commission merchants, swap dealers and major swap participants, referred to as registrants, that provides relief from certain...more
On January 23, the National Futures Association (NFA) issued a notice informing its members that the annual reports required by NFA rules to be submitted by the chief compliance officer (CCO) of a swap dealer (SD) or major...more
On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that extends the deadline for submitting the annual report that must be...more
On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued guidance regarding the annual reports that must be filed by the chief compliance officer (CCO)...more
On December 22, 2014, the Division of Swap Dealer and Intermediary Oversight (“DSIO”) of the Commodity Futures Trading Commission (“CFTC”) issued an Advisory providing guidance regarding the contents of chief compliance...more
Annual Report Advisory - On December 22, 2014, the Division of Swap Dealer and Intermediary Oversight (Division) of the U.S. Commodity Futures Trading Commission (CFTC) released an advisory (Advisory) providing...more
2014 ANNUAL MEETING SEASON - Dear clients and friends, We present to you our traditional year-end issue of Snell & Wilmer’s Corporate Communicator to help you prepare for the upcoming annual report and proxy...more