Dodd-Frank Wall Street Reform and Consumer Protection Act Commodities Futures Trading Commission

The Dodd-Frank Wall Street Reform and Consumer Protection Act is a United States federal statute signed into law on July 21, 2010. The Act was passed in response to the Great Recession of the late 2000s and... more +
The Dodd-Frank Wall Street Reform and Consumer Protection Act is a United States federal statute signed into law on July 21, 2010. The Act was passed in response to the Great Recession of the late 2000s and includes broad reforms related to many aspects of the financial and banking industry. Notable sections of the Act include stricter regulations of the derivatives market, as well as the Volcker Rule, which restricts the trading practices of FDIC-insured institutions.    less -
News & Analysis as of

Dodd-Frank Implementation Update: Key Differences Between the CFTC and SEC Final Business Conduct Standards and Related...

The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more

CFTC Proposes to Allow Private Lawsuits for Transactions in RTOs and ISOs

The proposal could create uncertainty for market participants and raise jurisdictional questions about which regulator should police power markets....more

Citadel, a $24-Billion Hedge Fund, Seeks Whistleblower Status

Just a few months after announcing the first-ever award to an outside whistleblower, federal authorities may be on the verge of expanding the reach of whistleblower incentives even further. Last week, Citadel, the...more

SEC Issues Business Conduct Rules for Security-Based Swap Entities

In an important step in the ongoing regulation of the market for security-based swaps (both individually and in the plural, “SBS”), last month the Securities and Exchange Commission (“SEC”) issued its final business conduct...more

Compliance Departments Must Continue to Evolve as Regulators Refine Their Approach to Spoofing

The government’s pursuit of alleged “spoofing” continues to garner headlines with the criminal authorities recently securing a conviction in the prosecution of Michael Coscia for alleged spoofing on the Chicago Mercantile...more

CFTC announces its largest whistleblower award to date – key takeaways

The US Commodity Futures Trading Commission has announced its third and largest whistleblower award to date – an award of more than $10 million – to a whistleblower who provided information that led to a successful CFTC...more

Derivatives in Review - April 2016

Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more

U.S. Department of Labor Finalizes Fiduciary Definition and Conflict of Interest Rule

On April 6, 2015, the U.S. Department of Labor (Department) issued its highly anticipated final rule addressing when a person is considered to be a fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA)...more

CFTC Proposed Guidance on Gas and Capacity Contracts Further Reduces Dodd-Frank Swap Burdens on End-Users

On April 4, 2016, the Commodity Futures Trading Commission (CFTC) issued proposed guidance that two products – common in competitive wholesale electric and natural gas markets – would not be considered swaps under the...more

This Is Not a Test: The CFTC Joins the SEC and IRS in Awarding Substantial Whistleblower Bounties

Who can tune out those periodic blaring interruptions to our favorite television programs? This is a test. For the next 60 seconds, this station will conduct a test of the Emergency Broadcast System. This is only a test. In...more

CFTC Announces $10 Million Whistleblower Award, Its Largest Award Yet

The Commodity Futures Trading Commission (“CFTC”) recently announced the largest ever award under its Whistleblower Program created by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The whistleblower...more

A Review of Recent Whistleblower Developments

SEC Awards Bounty to Whistleblower, But Offsets Award for a Judgment Against the Whistleblower - The extent to which the SEC would reward whistleblowers, who themselves engaged in wrongdoing, has been the subject of...more

CFTC Issues Record-High Whistleblower Bounty Award

On April 4, 2016, the U.S. Commodity Futures Trading Commission (CFTC) issued its third and largest award, of more than $10 million, as part of its Dodd-Frank whistleblower program. As was the case with the CFTC’s two...more

Bridging the Week - April 2016 #2

CFTC Again Extends Deadlines for New OCR Compliance; Puts Pressure on FCM Clients Who Will Not Provide Adequate Information Regarding Trading Control - Late last week, staff of the Division of Market Oversight of the...more

U.S. Commodity Futures Trading Commission Awards Record $10 Million to Whistleblower

The U.S. Commodity Futures Trading Commission (CFTC) announced on April 4, 2016 that it awarded over $10 million to a whistleblower.  This is the largest award made by the CFTC’s Whistleblower Program.  ...more

CFTC Proposes Dodd-Frank Relief to Certain Energy Industry Contracts

The proposal furthers an ongoing effort to minimize Dodd-Frank burdens on commercial end users. On April 4, the US Commodity Futures Trading Commission (CFTC) issued an order proposing guidance about the Dodd-Frank...more

CFTC’s Publication of Largest Whistleblower Award Follows Increased Focus on Whistleblowing Initiatives

On April 4, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) announced the issuance of a whistleblower award of more than $10 million for original information that it said led to a major enforcement action over...more

CFTC Announces Its Largest Whistleblower Award to Date

The Commodity Futures Trading Commission (“CFTC”) yesterday announced by far its largest whistleblower award to date, agreeing to pay “more than $10 million” to a whistleblower who provided key information leading to a...more

CFTC Further Reduces Regulatory Burdens Associated with Commodity Options

On March 16, 2016, the U.S. Commodity Futures Trading Commission (CFTC) took action to further reduce the regulatory requirements associated with commodity trade options through issuance of a final rule that took effect on...more

CFTC Finalizes Relief from Trade Option Reporting and Recordkeeping Requirements for Commercial End Users

On March 16, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) approved a final rule that eliminates the reporting and recordkeeping requirements in current CFTC regulations for trade option counterparties that are...more

CFTC Approves Amendment to Trade Options Exemption

The CFTC recently amended its trade option exemption to exclude certain reporting and recordkeeping requirements if a party to the option is a commercial end user of the underlying commodity. The broadened exemption provides...more

This Week In Securities Litigation

The SEC filed its first action against a municipal adviser for breach of fiduciary duty based on a provision amended by Dodd-Frank. The agency also continued to file insider trading actions in an administrative forum....more

CFTC Provides Delivery Method for Volcker Rule CEO Attestation

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission, or CFTC, announced that certain banking entities subject to Appendix B of Part 75 of the Commission’s regulations should...more

No-Action Relief from CFTC Rule 3.10(c)(3) Clearing Requirement

CFTC grants no-action relief regarding the application of the exemption in CFTC Rule 3.10(c)(3) to swaps that are not subject to a clearing requirement. On February 12, 2016 the Commodity Futures Trading Commission...more

Mandatory Margin Posting Regulations Coming Soon for Uncleared Swaps

U.S. bank regulators recently adopted final rules establishing initial and variation margin requirements for uncleared swaps (Final Margin Rules). These rules apply to regulated entities such as banks and subsidiaries of bank...more

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