Podcast: CFTC Issues LIBOR Transition Relief for Swaps
LEGAL ALERT: CFPB Issues Proposed Revisions to No-Action Letter Policy
Open for Business: SEFs Navigate the New Regulatory Environment
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more
We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more
BROKER-DEALER - FINRA Proposes to Ease Restrictions on Initial Equity Public Offerings and New Issues - The Financial Industry Regulatory Authority (FINRA) is proposing to amend its Rule 5130 and Rule 5131 to ease ...more
The staff of the Securities and Exchange Commission (SEC) has informally provided Vedder Price with key interpretive guidance clarifying the transition period disclosure requirements for issuers of variable insurance products...more
During 2018, the SEC issued rule updates and guidance that are intended to ease certain public reporting requirements and clarify the SEC’s position with respect to the shareholder proposal process. While the SEC is taking...more
For decades, mutual fund directors have turned to quarterly reports on affiliated cross trades, participation in affiliated underwritings and affiliated brokerage; the reports themselves state that the trades are in...more
The SEC has previously provided guidance on the filing of annual and supplemental reports required under Rule 17a-5 or Rule 17a-12 by broker-dealers or over-the-counter derivatives dealers on the SEC EDGAR system. However,...more
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
The CFTC provides the market additional time to submit Form TO while considering further amendments to trade option reporting rules. On February 18, 2016, the US Commodity Futures Trading Commission's (the CFTC) Division...more
On November 9, the U.S. Commodity Futures Trading Commission’s (the “CFTC“) Division of Market Oversight issued a time-limited no-action letter extending the relief provided in CFTC Letter No. 14-141. The relief applies to...more
CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps - On August 19, The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments to existing rules relating...more
Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more
On January 23, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter regarding financial reporting requirements as they apply to foreign introducing...more
Reuters has an interesting article about a no-action letter the CFTC issued to Southwest Airlines to permit a 15 calendar day delay in reporting oil derivative transactions. Southwest apparently convinced the CFTC that rapid...more
On October 8, the Commodity Futures Trading Commission’s Divisions of Market Oversight and Clearing and Risk (Divisions) issued No-Action Letter No. 14-122 providing relief to Singapore Exchange Derivatives Clearing Limited...more
The staff of the Commodity Futures Trading Commission (CFTC) published a no-action letter on September 9, 2014 (available here) that permits certain commodity pool operators (CPOs) to conduct general solicitation in private...more
The conditional, time-limited no-action letter extends certain compliance deadlines under the new rules. On November 18, 2013, the US Commodity Futures Trading Commission (CFTC) published final rules on Ownership and...more
In this issue: - SEC Issues Statement on the Effect of the Recent US Court of Appeals Decision on the Conflict Minerals Rule - CFTC Extends Relief From Oral Communication Recording Requirement - CFTC...more
In this issue: - Proposed Amendments to Delaware General Corporation Law and Courts and Judicial Procedure Law - SEC Division of Corporation Finance Issues New C&DIs Relating to Social Media Use - FINRA...more
In this issue: - FINRA Issues Annual Regulatory and Examination Priorities Letter for 2014 - CFTC Makes Comparability Determinations for Substituted Compliance Purposes - CFTC Issues No-Action Relief from...more
Commodity Futures Trading Commission staff released several no-action letters impacting swap execution facilities (SEFs) and their participants. These no-action letters are related to swap data reporting requirements, SEF...more
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
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 Letters ...more
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