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
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
On November 16, 2012, the Department of the Treasury issued a final determination exempting both foreign exchange swaps ("FX swaps") and foreign exchange forwards ("FX forwards") from regulation as "swaps" under the Commodity...more
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
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
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