Dodd-Frank Wall Street Reform and Consumer Protection Act Major Swap Participants

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 -
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"SEC Finalizes Registration Rules for Security-Based Swap Entities"

On August 5, 2015, the Securities and Exchange Commission (SEC) adopted final registration rules for security-based (SB) swap dealers and major SB swap participants (collectively SBS Entities). Concurrently, the SEC also...more

CFTC Issues Proposed Rules on Cross-Border Uncleared Swap Margin Requirements

The CFTC has combined an entity-level approach with a transaction-level approach in its proposed cross-border uncleared swap margin requirements. Introduction - On October 3, 2014, the Commodity Futures Trading...more

CFTC Proposes Rule on Margin Requirements for Uncleared Swaps in Cross-Border Transactions

On June 29, the Commodity Futures Trading Commission proposed a rule that is intended to clarify the extent to which covered swap entities must comply with CFTC’s margin rules for uncleared swaps in cross-border transactions....more

CFTC Revises Seven-Part Test for Forward Contracts with Embedded Volumetric Optionality

On May 18, 2015, the Commodity Futures Trading Commission (“CFTC”) published a final interpretation on forward contracts with embedded volumetric optionality (“Final EVO Interpretation”).1 In the Final EVO...more

SEC’s Proposed SBS Rules on Cross-Border Security-Based Swap Activities

When the Securities and Exchange Commission (SEC) adopted final rules in June 2014 on the cross-border activities of security-based swap (SBS) dealers and major SBS participants, the SEC indicated that it would reserve the...more

Dodd-Frank Update: CFTC Proposes to Reduce Trade Option Obligations for End Users

On April 30, 2015, the Commodity Futures Trading Commission (“CFTC”) issued a notice of proposed rulemaking (“NOPR”) proposing to reduce certain reporting and recordkeeping requirements for end users. Notably, the NOPR...more

House Bill Seeks to Limit Certain Provisions of Dodd-Frank

On Jan. 14, 2015, the effort to repeal or amend certain provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) continued in the heavily Republican House of Representatives with the...more

Regulators Re-Propose Minimum Margin Requirements for Uncleared Swaps

U.S. Federal banking regulators (the “Prudential Regulators”) recently re-proposed rules providing for minimum margin requirements for uncleared swaps and security-based swaps executed by swap dealers, security-based swap...more

Regulators Publish Re-proposed Margin Requirements for Uncleared Swaps

On September 3, 2014, the Board of Governors of the Federal Reserve System (the Board) jointly adopted, with certain federal banking regulators, re-proposed rules that will require registered swap dealers, security-based swap...more

Bank Regulators Propose Relaxed Margin Requirements for Corporate End Users of Uncleared Swaps

Five federal agencies have taken a second stab at a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap dealers, and major security-based swap participants as...more

Federal Agencies Seek Comment on Swap Margin Requirements

On September 3, the Fed, the Farm Credit Administration, the FDIC, the FHFA, and the OCC sought comment on a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap...more

SEC Adopts Final Rules and Guidance Regarding the Cross-Border Application of “Security-Based Swap Dealer” and “Major...

Nearly four years after the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), on June 25, 2014, the Securities and Exchange Commission (“SEC”) adopted its first in a series of...more

SEC Finalizes Cross-Border Rule for Security-Based Swaps

On June 25, 2014, the United States Securities and Exchange Commission (“SEC”) adopted the first in a series of final rules and interpretive guidance related to U.S. regulation of cross-border security-based swap activities....more

SEC to Hold Open Meeting on Cross-Border Security-Based Swap Definitions

On June 18, the Securities and Exchange Commission announced that it will hold an open meeting on June 25 to consider whether to adopt rules that would apply the definitions of “security-based swap dealer” and “major...more

SEC Proposes Securities-Based Swap Recordkeeping, Reporting and Notification Requirements

On May 2, 2014, the Securities and Exchange Commission (SEC)published in the Federal Register proposed regulations1 that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street...more

CFTC Hosts End-User Roundtable

The Commission responds to issues facing end-users as a result of derivatives reforms. Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the Commodity Exchange Act...more

SEC SBSD Recordkeeping And Reporting Proposal

The SEC has published proposed recordkeeping, reporting and capital deficiency notification requirements that would apply to security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”) as well...more

A Simple Framework for Determining Whether Dodd-Frank Applies to Your Energy Trade

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank” or the “Act”) authorizes the Commodity Futures Trading Commission (“CFTC”) to comprehensively regulate energy trading activities. Dodd-Frank is...more

"CFTC Expands Large Trader Reporting and Increases Customer Account Protection Requirements"

The Commodity Futures Trading Commission (CFTC or Commission) recently adopted several rules to improve large trader reporting, facilitate segregation of customer swap margin and enhance customer protections for futures and...more

CFTC Guidance on Cross-Border Application of United States Swap Regulations

Introduction - On July 12, 2013, the Commodity Futures Trading Commission (the “CFTC”) adopted interpretive guidance (the “Guidance”) that details the CFTC’s interpretation of the application of the Commodity Exchange...more

Final Exemptive Order Regarding Cross-Border Application of Certain Swap Regulations

On July 13, 2013, the Commodity Futures Trading Commission (the “CFTC”) approved a second final exemptive order (the “Final Order”) providing time-limited relief from certain cross-border applications of the swaps provisions...more

An End-User's Guide to the CFTC's Final Cross-Border Guidance

Last month, the U.S. Commodity Futures Trading Commission (CFTC) issued final interpretive guidance with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank...more

CFTC Issues Final Guidance and Accompanying Exemptive Order on Cross-Border Application of Certain Swap Regulations

At a public meeting on July 12, 2013, the Commodity Futures Trading Commission (CFTC or Commission) adopted final guidance on how Dodd-Frank Act requirements will apply to cross-border swap activities (Guidance). In...more

CFTC Issues Interpretive Guidance Regarding Certain Cross-Border Transactions

On July 12, the Commodity Futures Trading Commission adopted interpretive guidance and a policy statement regarding the cross-border application of the swap provisions of the Dodd-Frank Wall Street Reform and Consumer...more

CFTC Adopts Final Cross Border Swaps Guidance

On Friday, the U.S. Commodity Futures Trading Commission (the “CFTC”) adopted final guidance regarding the cross border application of the new derivatives requirements under the Dodd-Frank Wall Street Reform and Consumer...more

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