DSIO

News & Analysis as of

CFTC Guidance on FCM and DCO Investments in Money Market Funds

Divisions of the U.S. Commodity Futures Trading Commission (CFTC) on August 8, 2016 issued letters restricting futures commission merchants (FCMs) and derivatives clearing organizations (DCOs) from investing in money market...more

Orrick's Financial Industry Week in Review

Financial Industry Developments - CFTC Announces Measures to Enhance Protection of Customer Funds - On August 8, 2016, the U.S. Commodity Futures Trading Commission (CFTC) announced three separate enhancements...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

CFTC Staff Issues No-Action Relief Helpful for Non-U.S. Commodity Pool Operators and Commodity Trading Advisors

The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more

CFTC Extends Relief for Non-US Swap Dealers From Transaction-Level Requirements

On August 13, the Division of Swap Dealer and Intermediary Oversight, Division of Clearing and Risk, and Division of Market Oversight of the Commodity Futures Trading Commission extended no-action relief from certain...more

CFTC and NFA Afford Relief from Certain CTA Periodic Reporting Obligations

On July 21, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) published an exemptive letter that provides relief from periodic reporting on CFTC Form...more

CFTC Staff Exempts Certain CTAs From Filing Form CTA-PR

On July 21, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) granted exemptive relief to certain commodity trading advisors (CTAs) from the requirement in CFTC Regulation...more

Bridging the Week - July 2015 #4

FC Stone Companies and Goldman Sachs Receive Largest Fines in CME Group’s 27 Disciplinary Actions Cascade: CME Group handed down sanctions in 27 separate disciplinary actions last week for alleged violations of rules...more

Corporate & Financial Weekly Digest - Volume X, Issue 27

In this issue: - Court of Appeals for Third Circuit Overturns District Court Ruling Regarding Exclusion of Shareholder Proposal From Proxy Statement - FINRA Updates Its Interpretation of the SEC's Financial...more

CFTC Issues Relief From IB and CTA Registration to Foreign Persons Dealing in Swaps for International Financial Institutions

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from introducing broker (IB) and commodity trading advisor (CTA) registration to persons...more

Corporate & Financial Weekly Digest - Volume X, Issue 23

In This Issue: - Meeting of the SEC Advisory Committee on Small and Emerging Companies - FINRA Requests Comment on a Proposed Rule to Require Delivery of an Educational Communication to Customers of a Transferring...more

Orrick's Financial Industry Week in Review

SEC Provides Additional Analysis Related to Proposed Pay Ratio Disclosure Rules - On June 4, the Securities and Exchange Commission provided additional analysis related to its proposed rules for pay ratio disclosure. The...more

CFTC Staff Issues No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Persons Located Outside...

On June 4, the Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued a No-Action Letter stating that it will not recommend that the CFTC take action for failure to...more

CFTC Staff Issues No-Action Letters Relating to Swaps Trading Platforms in Australia

On May 19, the Commodity Futures Trading Commission issued two no-action letters granting relief to certain swaps trading platforms in Australia and participants executing swaps transactions on such platforms....more

NFA Updates BASIC to Assist With Bylaw 1101 Diligence on Delegating CPOs

The National Futures Association (NFA) has updated its Background Affiliation Status Information Center (BASIC) system to help NFA members conducting Bylaw 1101 due diligence to determine whether the commodity pool operator...more

CFTC Extends CCO Report Filing Deadline

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued permanent no-action relief from the filing deadline for chief compliance officer (CCO) annual reports....more

CFTC Issues Relief to Swap Dealers Regarding Legacy SPV Swaps

The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued no-action relief to swap dealers (SDs) from certain business conduct standards in dealing with...more

CFTC Staff Issues No-Action Relief Regarding CCO Annual Report Timing Requirement

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

CFTC Staff Issues No-Action Relief for Swaps with Legacy SPVs

On March 31, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to provisionally registered swap dealers (SDs) from complying with certain specified regulations when...more

Corporate & Financial Weekly Digest - Volume X, Issue 13

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

CFTC Issues Advisory on Reporting Obligations Pursuant to the Ownership and Control Final Rule

On March 23, CFTC Division of Market Oversight and Division of Swap Dealer and Intermediary Oversight issued a staff advisory to remind certain reporting parties (including futures commission merchants, clearing members,...more

CFTC Issues No-Action Relief for Amended Legacy Swaps between SDs and SPVs

On March 31, 2015, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”) issued no-action relief regarding compliance with certain of its swap...more

CFTC Issues Advisory on Ownership and Control Reporting

The Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission have issued an advisory on ownership and control reporting (OCR) for futures...more

"CFTC Extends Annual Report Deadline for Certain Chief Compliance Officers"

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

U.S. Commodity Futures Trading Commission Grants Relief From Commodity Pool Operator Obligations Concerning Insurance-Linked...

In CFTC Letter No. 14-145 Exemption (November 12, 2014) and CFTC Letter No. 14-152 No-Action (December 18, 2014), the U.S. Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO)...more

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