Simple Agreements for Future Tokens pose difficult and controversial legal questions under U.S. securities, commodities and tax laws. SAFT holders face significant difficulties in securing liquidity, and regulatory issues...more
With recent release, the CFTC hopes to eliminate market uncertainty on forward contracts with embedded volumetric optionality. UPDATE (June 18, 2015): On May 12, 2015, the CFTC adopted the Proposal as proposed (as used...more
In 2012, the Commodity Futures Trading Commission issued an interpretation that identifies the circumstances in which an agreement, contract or transaction would fall within the forward contract exclusions from the “swap” and...more
On November 13, 2014, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) approved for publication in the Federal Register a proposed interpretation clarifying the CFTC’s...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) added provisions to the Commodity Exchange Act (“CEA”) regarding the regulatory oversight of swaps transactions that have imposed unintended and...more