Compliance Commodities Futures Trading Commission

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
News & Analysis as of

House Approves CFTC Reauthorization, Changes to Dodd-Frank

After a nearly two year process, on June 24, 2014, the U.S. House of Representatives voted 266-144 to pass H.R. 4413, the Customer Protection and End-User Relief Act, which would reauthorize the Commodity Futures Trading...more

Financial Regulatory Developments Focus - July 2014

In this issue: - Derivatives - Compensation - Regulatory Capital - Credit Ratings - Financial Market Infrastructure - Financial Services - Funds - Enforcement...more

Legal Alert: CFTC Division of Market Oversight Releases Questions for June 19 Roundtable on Position Limits

The Commodity Futures Trading Commission (CFTC) will host a public roundtable on June 19, 2014, to discuss questions related to a proposed rulemaking to establish speculative position limits for 28 exempt and agricultural...more

CFTC Issues No Action Letter On Application Of Swap Rules To Longevity Reinsurance Transaction

There has been considerable concern in the insurance and reinsurance industries that certain hedging and reinsurance activities that companies have engaged in for a number of years, particularly with respect to life insurance...more

Financial Regulatory Developments Focus - June 2014 #2

In this issue: - Derivatives - Capital and Prudential Regulation - Remuneration - Credit Ratings - Funds - Financial Services - Enforcement - Events -...more

CFTC Extends No-Action Relief for Certain Transaction-Level Requirements for Non-US Swap Dealers

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01...more

U.S. Commodity Futures Trading Commission Issues First Whistleblower Award

On Monday, May 19, 2014, the U.S. Commodity Futures Trading Commission (“CFTC”) issued its first award to a whistleblower under its Dodd-Frank bounty program. ...more

Orrick's Financial Industry Week in Review

EU Commission Sends Statement of Objections to Three Banks in Cartel Investigation - On May 20, the European Commission announced that it has sent a statement of objections to Credit Agricole, HSBC and JP Morgan for...more

Corporate and Financial Weekly Digest - Volume IX, Issue 21

In this issue: - CME Delays Prohibition on Transitory EFRPs - JAC Issues Guidance on Margin Funds - CFTC Hands Out First Whistleblower Award - NFA Adopts Fee for Registration...more

Legal Alert: CFTC Adopts Streamlined Approach for Delegation of CPO Registration

On May 12, 2014, the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued a staff letter (the Staff Letter) that provides a streamlined approach for commodity pool...more

This Week In Securities Litigation (Week ending May 16, 2014)

The Commission got split decisions in court this week. It prevailed in one high profile trial, obtaining a jury verdict in its favor. It lost a significant summary judgment motion regarding the statute of limitations...more

The Financial Report - Volume 3, No. 10 • May 2014 (Global)

News from the Americas - High-speed trading. Bloomberg discussed US Senate Agriculture Committee hearings on high-speed trading. Former CFTC economist Andrei Kirilenko said that new books and records requirements and...more

Orrick's Financial Industry Week In Review

Council of the EU Adopts Bank Recovery and Resolution Directive - On May 6, the Council of the EU adopted at first reading the text of the Bank Recovery and Resolution Directive (BRRD). The BRRD seeks to harmonize...more

Corporate and Financial Weekly Digest - Volume IX, Issue 17

In this issue: - Proposed Amendments to Delaware General Corporation Law and Courts and Judicial Procedure Law - SEC Division of Corporation Finance Issues New C&DIs Relating to Social Media Use - FINRA...more

Dodd-Frank Compliance in a Nutshell

Here are some important Dodd-Frank rules that you need to keep in mind if you are neither a Swap Dealer nor a Major Swap Participant ("Non-SD/MSP"). Clearing - General Rule. Dodd-Frank requires all swaps listed...more

CFTC Outlines GLB Act Privacy Best Practices

Recently, the CFTC’s Division of Swaps Oversight issued Staff Advisory No. 14-21, which recommends best practices for CFTC-regulated intermediaries to comply with applicable Gramm-Leach-Bliley (GLB) Act privacy requirements,...more

CFTC Issues Advisory on Compliance with Gramm-Leach-Bliley Act Security Safeguards

On February 26, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission issued Advisory 14-21 to provide futures commission merchants, commodity trading advisors, commodity...more

Corporate and Financial Weekly Digest - Volume IX, Issue 9

In this issue: - CFTC Issues Advisory on Compliance with Gramm-Leach-Bliley Act Security Safeguards - SEC Issues Guidance on Aggregate Advisory Fee Rates for Multi-Manager Funds - Supreme Court Rules that...more

2014 Compliance Checklist for Investment Advisers

For those of you still easing into 2014, we thought that now would be a good time to help you plot out your regulatory and internal compliance schedules for the upcoming calendar year....more

The Gift That Keeps On Giving: CFTC’s Misaligned Definition of Forward Contracts Gives Rise to Another Potential Burden on LDCs...

In our recent post, “CFTC Forward vs. Trade Option: LDCs Still Struggle as Trade Option Reporting Deadline Looms,” we discussed the unintended impact of the Dodd-Frank Wall Street Reform and Consumer Protection Act...more

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

Private Fund Update - February 18, 2014

In this issue: - The 113th Congress - Securities and Exchange Commission - Commodity Futures Trading Commission (CFTC) - The Administration - Congressional Budget Office (CBO) - Small...more

Commodity Pool Operators and Commodity Trading Advisors: Are Enhanced Customer Protections on the Horizon?

On January 23, 2014, the National Futures Association (NFA) issued a Request for Comments from commodity pool operators (CPOs) and commodity trading advisors (CTAs) as to whether the NFA should adopt rules to: (1) ensure that...more

Time-Limited No-Action Relief From Compliance With Certain Conditions Associated With the Receipt of Customer Funds by Futures...

On January 10, 2014, the US Commodity Futures Trading Commission's ("CFTC") Division of Swap Dealer and Intermediary Oversight (the "Division") issued a time-limited no-action letter in response to a letter sent on behalf of...more

Private Funds In Focus - Winter 2014

Year End Update – Compliance: Certain Upcoming U.S. Regulatory Deadlines - The list below briefly summarizes various regulatory obligations and filing deadlines for private fund managers under U.S. rules....more

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