Final Rules Commodities Futures Trading Commission

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US Commodity Futures Trading Commission Approves Final Rule on Amendments to the Swap Portfolio Reconciliation Requirement

The Commodity Futures Trading Commission approved a final rule to amend a requirement found in CFTC Regulation 23.500(i) that swap dealers and major swap participants exchange the terms of swaps with their counterparties for...more

No-Action Relief Regarding Masking Information Reportable under the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the masking of information reportable under the ownership and control final rule (the “OCR...more

No-Action Letter Issued Regarding the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the ownership and control final rule (the “OCR Final Rule”). The OCR Final Rule requires...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

Bridging the Week - April 2016 #3

SEC Adopts Swaps Business Conduct Rules Different From Comparable CFTC Requirements: Last week the Securities and Exchange Commission adopted final rules imposing business conduct standards on registered security-based...more

The CFTC Announces Final Rule for Alternative to Fingerprinting for Foreign Natural Persons

On March 28, 2016, the U.S. Commodity Futures Trading Commission (CFTC) approved a final rule that will add an alternative method of CFTC registration for foreign natural persons. The CFTC will now accept a registered firm’s...more

US Commodity Futures Trading Commission Approves Final Rule to Amend the Trade Option Exemption

The Commodity Futures Trading Commission approved a final rule that removes certain reporting and recordkeeping requirements for trade option counterparties that are neither swap dealers nor major swap participants...more

CFTC Approves Final Rule Eliminating Certain Reporting and Recordkeeping Requirements for Trade Option End-Users

On March 16, the Commodity Futures Trading Commission unanimously approved a final rule removing reporting and recordkeeping requirements for trade option counterparties that are neither swap dealers nor major swap...more

CFTC Approves Final Rule to Amend the Trade Option Exemption by Eliminating Certain Reporting and Recordkeeping Requirements for...

On March 16, the U.S. Commodity Futures Trading Commission approved a final rule that eliminated certain requirements “for trade option counterparties that are neither swap dealers nor major swap participants[.]”...more

Corporate and Financial Weekly Digest - Volume XI, Issue 11

CFTC - CFTC Approves Final Rule Eliminating Certain Reporting and Recordkeeping Requirements for Trade Option End-Users - On March 16, the Commodity Futures Trading Commission unanimously approved a final rule...more

CFTC Adopts Final Trade Option Rule

On March 16, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved amendments to the rules applicable to certain physically-settled options referred to as “trade options.” This final rule substantially...more

CFTC Eliminates Certain Trade Option Reporting and Recordkeeping Requirements for End Users

The CFTC approved a final rule today that removes trade option* reporting and recordkeeping requirements applicable to non-swap dealer/major swap participant counterparties (“Non-SD/MSPs” or “end users” for purposes of this...more

Prudential Regulators and CFTC: Final Margin Rules for Uncleared Swaps

The Prudential Regulators and the CFTC release final initial and variation margin rules for uncleared swaps and security-based swaps. On October, 22 2015, the Prudential Regulators released final rules and accompanying...more

SEC Adopts Rule Amendments Addressing Dealing Transactions Between Non-U.S. Persons that are “Arranged, Negotiated, or Executed”...

On February 10, 2016, the U.S. Securities and Exchange Commission (“SEC”) approved final rule amendments to its cross border rules that address how the security-based swap dealer definition applies to security-based swap...more

CFTC Amends Regulation 1.35

U.S. Commodity Futures Trading Commission (CFTC) Regulation 1.35 requires futures commission merchants (FCMs), retail foreign exchange dealers (RFEDs), introducing brokers (IBs) and members of a swap execution facility (SEF)...more

CFTC Adopts Uncleared Swaps Margin Rules

On December 16, 2015, the Commodity Futures Trading Commission (“CFTC” or “Commission”) adopted final rules to impose margin requirements on uncleared swaps entered into by swap dealers and major swap participants subject to...more

CFTC Adopts Final Margin Rules for Swap Dealers

On December 16, the Commodity Futures Trading Commission adopted final rules that set margin requirements for swap dealers and major participants (collectively, Swap Entities) regulated by the CFTC with respect to swaps that...more

CFTC Approves Final Rule on Margin Requirements for Uncleared Swaps

The U.S. Commodity Futures Trading Commission (CFTC) approved on December 16 final rules (Final Rules) on margin requirements for over-the-counter uncleared swaps entered into by CFTC-registered swap dealers (SDs) and major...more

CFTC Adopts Margin Requirements for Uncleared Swaps

Wednesday, the Commodity Futures Trading Commission (“CFTC”) held an open meeting at which it voted to adopt final rules (the “CFTC Margin Rules”) governing margin requirements for uncleared swaps (“Swaps”) entered into by...more

Prudential Regulators Adopt Final Rule for Margin on Non-cleared Swaps and Non-cleared Security-Based Swaps

On October 22, 2015, the Board of Directors of the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Farm Credit Administration and...more

"Prudential Regulators Finalize Margin Requirements for Non-Cleared Swaps"

Federal banking regulators (Prudential Regulators) have finalized much-anticipated rules (Final Rules) relating to initial and variation margin requirements for certain swaps and security-based swaps that are not centrally...more

CFTC’s Division of Market Oversight Provides Additional Time to Comply with Electronic Reporting Requirements in the OCR Final...

On September 28, the U.S. Commodity Futures Trading Commission’s (the “Commission”) Division of Market Oversight issued a no-action letter that provides reporting parties additional time to comply with certain reporting...more

Orrick's Financial Industry Week in Review

SEC Proposes to Amend Rules Governing Its Administrative Proceedings - On September 24, the U.S. Securities and Exchange Commission (the "SEC") proposed to amend rules governing its administrative proceedings. Key...more

CFTC Requires Introducing Brokers, Commodity Pool Operators, and Most Commodity Trading Advisors That Use Swaps to Become Members...

On September 14, 2015, the Commodity Futures Trading Commission (CFTC) published a final rule requiring introducing brokers (IBs), commodity pool operators (CPOs), and most commodity trading advisors (CTAs) to become members...more

CFTC Approves Final Regulation Regarding Requirement to be a Member of a Registered Futures Association

On September 10, the U.S. Commodity Futures Trading Commission Division issued a final rule requiring that all registered introducing brokers and commodity pool operators, and certain commodity trading advisors become and...more

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