News & Analysis as of

CFTC Extends Deadline to Comply with Certain Trading Documentation Requirements Under Dodd-Frank for Corporate End-Users of...

In late June 2013, the Commodity and Futures Trading Commission (CFTC) issued a no-action letter extending the period for certain corporate end-users of foreign exchange (FX) derivative transactions to comply with the trading...more

Imminent Dodd-Frank Compliance Issues for Users of Swaps and Derivatives

Implementation of the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) affecting users of swaps and derivatives has been moving forward. Numerous rules of the Commodity Futures...more

CFTC Issues No-Action Letters

The Commodity Futures Trading Commission (CFTC) released a series of staff letters relating to various issues arising under rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, including chief...more

Treasury Issues Foreign Currency Swap and Forward Exemption

The Commodity Exchange Act, or CEA, as amended by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, authorizes the Secretary of the Treasury to issue a written determination that foreign exchange...more

CFTC Affords Relief and Guidance in Light of Final Swap Definition’s Effective Date

On October 12, 2012, the Commodity Futures Trading Commission’s (CFTC) and Securities and Exchange Commission’s (SEC) final rules to further define the term “swap” (among other terms) became effective. The effective date of...more

Swap Definitions Rules Finalized by the SEC and the CFTC under Dodd-Frank

Introduction - On July 18, 2012, the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC” and, together with the SEC, the “Commissions”) jointly published several final rules...more

Update: Dodd-Frank Rules Impact End-Users of Foreign Exchange Derivatives - Companies That Hedge Foreign Exchange Exposures Need...

On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) was enacted. Title VII of Dodd-Frank amends the Commodity Exchange Act (CEA) and other federal securities laws to provide a...more

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