News & Analysis as of September 21, 2024

Major Swap Participants

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A Commodity Pool is an investment structure or enterprise where funds from a number of participants are combined into a single entity for the purpose of trading futures contracts, options on contracts, retail... more +

Customer Segregation: Keep It Separate

NFA Adopts Cybersecurity Guidance

Dechert LLP on 11/6/2015

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

CFTC Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

Foley Hoag LLP - Security, Privacy and the... on 10/30/2015

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs...more

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

Skadden, Arps, Slate, Meagher & Flom LLP on 9/14/2015

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

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

Akin Gump Strauss Hauer & Feld LLP on 8/22/2013

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

Mandatory Clearing of iTraxx CDS Indices for Category 2 Entities Began July 25

Katten Muchin Rosenman LLP on 7/30/2013

The Division of Clearing and Risk of the Commodity Futures Trading Commission announced that commodity pools, private funds (other than active funds) and certain other persons predominantly engaged in banking or financial...more

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