End-Users

Are End-User Agreements for Tangible Products on the Horizon?

by Scott & Scott, LLP on 5/8/2013

Scott & Scott, LLP attorney, Christopher Barnett, asks whether Google's Glass restrictive Terms of Service could be imitated by other consumer product manufacturers....more

Legal Alert: Nearly at the Buzzer, CFTC Affords End-Users Relief from Dodd-Frank Reporting Requirements

by Cheryl I. Aaron, James M. Cain, Doyle Campbell, Kalaundra Y. Carreathers, Warren N. Davis, Jacob Dweck, Daphne G. Frydman, Meghan R. Gruebner, Alexander S. Holtan, Meltem F. Kodaman, more +Catherine M. Krupka, David T. McIndoe, Raymond A. Ramirez, Mark D. Sherrill, R. Michael Sweeney, Jr. | Sutherland Asbill & Brennan LLP on 4/22/2013

On the brink of the compliance date for arguably one of the most burdensome requirements that end-users face under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Commodity Futures Trading...more

New Swap Business Conduct and Record-Keeping Regulations Kick in for Municipal Bond Issuers and Borrowers

by Nicholas Bentley, Meghan Burke, Charles Carey, Steve Ganis, Gregory Sandomirsky, Len Weiser-Varon | Mintz Levin - Public Finance on 4/18/2013

Beginning May 1, 2013, many new business conduct regulations adopted by the Commodity Futures Trading Commission (“CFTC”) pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) will begin to...more

FCC Seeks Comment on Bundled Components for E-rate

by Rebecca Jacobs, Mark Palchick | Womble Carlyle Sandridge & Rice, PLLC on 4/18/2013

Executive Summary: The Wireline Competition Bureau (“Bureau”) is seeking comment on proposed clarifications to the treatment of ineligible devices when bundled with E-rate eligible components....more

CFTC Staff Issues No-Action Letters

by Kevin M. Foley, Ross Pazzol, Adam J. Spector | Katten Muchin Rosenman LLP on 4/16/2013

Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more

Corporate and Financial Weekly Digest - April 12, 2013

by Katten Muchin Rosenman LLP on 4/15/2013

In this issue: - SEC and CFTC Adopt Joint Rules to Help Protect Investors from Identity Theft - CME Block Trade Advisories Clarify Nonpublic Information Restrictions - CFTC Staff Issues No-Action...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Delays April 10 Compliance Date for Many Swap Data Reporting Requirements"

by Maureen A. Donley, Elizabeth Doyle, Ryan Elsey, Joyce Penn Farnsworth, Ann Hawkins, Theodore M. Kneller, Daniel S. Konar II, Yossi Vebman, Mark D. Young | Skadden, Arps, Slate, Meagher & Flom LLP on 4/11/2013

On April 9, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight, responding to requests from multiple interested parties, issued a no-action letter (the No-Action Letter) extending the April...more

Reminder Regarding April 10 Deadline for Identifying Number Registration by Some Swap End-Users

by Nicholas Bentley, Len Weiser-Varon | Mintz Levin - Public Finance on 4/10/2013

This is a reminder that tomorrow, April 10, 2013, is the deadline for parties to certain swap agreements to obtain a CICI identifying number. The April 10 deadline applies to any party who entered into a swap after April 25,...more

CFTC Extends Compliance Dates For End User Swap Reporting

by Nate Endrud | Leonard, Street and Deinard - Dodd-Frank and... on 4/10/2013

The CFTC has issued a no-action letter that effectively extends the dates for swap counterparties who are not swap dealers (SDs) or major swap participants (MSPs) to come into compliance with the agency’s reporting rules...more

"CFTC No-Action Letter Relieves End-Users of Part 45 Reporting for Trade Options"

by Maureen A. Donley, Erik Elsea, Theodore M. Kneller, Daniel S. Konar II, Mark D. Young | Skadden, Arps, Slate, Meagher & Flom LLP on 4/8/2013

On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) provided end-users no-action relief (the No-Action Letter) from certain “trade option” reporting and recordkeeping...more

April 10 Deadline for Swap End User Legal Entity Identifier Requirement

by Guy C. Dempsey, Jr. | Katten Muchin Rosenman LLP on 4/3/2013

Every swap end user (i.e., any party to an outstanding derivative contract who is not a swap dealer or major swap participant) should be aware that April 10, 2013 is the deadline for obtaining a “CFTC Interim Compliant...more

CFTC Issues Advisory Regarding Swap Reporting Requirements

by Nate Endrud | Leonard, Street and Deinard - Dodd-Frank and... on 3/11/2013

The CFTC Division of Market Oversight has issued an advisory to remind market participants of the swap reporting requirements that are now, or soon to be, in effect. End users must be in compliance with the reporting rules...more

IECA Releases Amending Agreement To Facilitate End User Compliance With CFTC Regulations

by Nate Endrud | Leonard, Street and Deinard - Dodd-Frank and... on 3/11/2013

The International Energy Credit Association (“IECA”) has released a standardized agreement titled the “Dodd-Frank Act Representations and Reporting Amending Agreement” to facilitate end user compliance with the CFTC’s swap...more

Financial Services Legislative And Regulatory Update -- February 18‚ 2013

by Abby Matousek, Jason M. Rosenstock | Mintz Levin - Public Finance on 2/19/2013

In This Issue: Leading the Past Week; Legislative Branch; Executive Branch; and Upcoming Hearings. Excerpt from Leading the Past Week - President Obama touched on both new and old initiatives in his State of...more

End Users of Swaps: Deadline Extended for Swap Documentation to Comply with New Federal Requirements

by Peter Fanchi, Gregory Mennerick, Thomas Minogue, Gregory Omer, Richard Reibman | Thompson Coburn LLP on 2/8/2013

Federal authorities have extended the deadline imposed on swap dealers and major swap participants to amend swap documentation to comply with certain new legal requirements imposed by the Dodd-Frank Act. The deadline for...more

Compliance Considerations For Derivatives End-Users: A “How To Guide” to Basic Derivatives and Structured Products

by Brian Korn | Pepper Hamilton LLP on 1/24/2013

In This Presentation: - Dodd-Frank Protocol - Clearing - Clearing – End-User Exception - Important: Understand the Product Please see full presentation below for more information. ...more

Swap Clearing and the Commercial End User Exception: Corporate Governance and Risk Management Issues for Commercial Companies

by Juan Arciniegas, Anthony R.G. Nolan, Anh Tran | K&L Gates LLP on 1/18/2013

Central clearing of over-the-counter derivatives is a central pillar of the financial services reforms that are embodied in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The presumption...more

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