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No-Action Letters Swap Dealers

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - February 2024 - 2

Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Cadwalader, Wickersham & Taft LLP

Unpredictable Future of Political Prediction Markets

On August 4, the U.S. Commodity Futures Trading Commission (“CFTC”) had withdrawn its no-action letter (i.e., permission to operate) with respect to PredictIt, an online prediction market operated by the University of...more

Orrick, Herrington & Sutcliffe LLP

Extension of Brexit No-Action Letters

In November 2020, the CFTC published two no-action letters extending previously granted no-action relief related to Brexit. The relief was intended to provide “greater certainty to the global marketplace” in connection with...more

A&O Shearman

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

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The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more

Morrison & Foerster LLP

CFTC Issues No-Action Letters To Smooth The Road Away From The IBORs

On December 17, 2019, three different divisions of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters intended to facilitate the swaps market’s transition away from interbank offered rates (each, an...more

A&O Shearman

US Commodity Futures Trading Commission Issues No-Action Letters to Ensure Continued Relief and Substituted Compliance for U.K....

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The Commodity Futures Trading Commission has issued two no-action letters to ensure that existing regulatory relief and substituted compliance measures for EU firms will continue to apply to U.K. firms following the U.K.’s...more

Jones Day

CFTC Clears Decks for "No Deal" Brexit

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The Commodity Futures Trading Commission ("CFTC") extends no-action and exemptive relief from the European Union to the United Kingdom. On April 5, 2019, the CFTC's Divisions of Clearing and Risk, Market Oversight and Swap...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent SEC No-Action, Re-Proposal for Security-Based Swaps Focus on Comparability With Other US Regulators

In recent days, the Securities and Exchange Commission (SEC) announced a no-action position on enforcing its 2016 Business Conduct Standards against security-based swap dealers (SBSDs) and major security-based swap...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

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On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more

A&O Shearman

US Commodity Futures Trading Commission Staff Extends Time-Limited No-Action Relief on the Applicability of Transaction-Level...

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The U.S. Commodity Futures Trading Commission’s (CFTC) Divisions of Swap Dealer and Intermediary Oversight (DSIO), Clearing and Risk, and Market Oversight issued a time-limited no-action letter providing relief to certain...more

A&O Shearman

US Commodity Futures Trading Commission Issues Time-Limited No-Action Transition for March 1, 2017 Compliance Date for Variation...

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US Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a time-limited no-action letter (CFTC staff letter 17-11) which provides that, from March 1, 2017 to September 1,...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more

Orrick - Finance 20/20

CFTC Issues No-Action Letter to Swap Dealers to Extend Collateral Rule Deadline due to Limitations with Custodial Accounts

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On September 1, 2016, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealer and Intermediary Oversight announced that it “issued a time-limited, no-action letter stating that it will not recommend...more

Orrick - Finance 20/20

U.S. Swap Dealers and Non-U.S. Major Swap Participants Under SDR Reporting Rules

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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

Katten Muchin Rosenman LLP

No-Action Relief Granted to Foreign Branch of US Swap Dealer for Transaction-Level Requirements

In a recently released no-action letter, the Commodity Futures Trading Commission indicated it would not seek enforcement action against a US swap dealer and its counterparties where a foreign branch of the US swap dealer...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

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

Orrick - Finance 20/20

CFTC Extends No-Action Relief to Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations

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On June 15, CFTC Division of Market Oversight published a letter extending the time-limited relief provided by previously issued no-action letter 14-90, expiring on June 30, 2015, to June 30, 2016. The relief applies to the...more

Goodwin

Financial Services Weekly News Roundup - June 2015 #3

Goodwin on

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

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters Relating to Swaps Trading Platforms in Australia

On May 19, the Commodity Futures Trading Commission issued two no-action letters granting relief to certain swaps trading platforms in Australia and participants executing swaps transactions on such platforms....more

Miller & Martin PLLC

CFTC Issues Additional Relief for Family Offices

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In November 2012, the CFTC's Division of Swap Dealer and Intermediary Oversight issued a no-action letter stating that the Division would not recommend that the CFTC take enforcement action against a family office for failure...more

Katten Muchin Rosenman LLP

CFTC Extends Relief to FCMs from Certain Commingling Requirements

On June 25, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) extended to October 31 the relief previously granted in CFTC No-Action Letters Nos. 14-02 and 14-45....more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 26

In this issue: - Delaware Fee-Shifting Legislation Delayed - SEC Orders Securities Exchanges and FINRA to Develop Tick Size Pilot Plan - CFTC Extends Relief to FCMs from Certain Commingling Requirements ...more

Katten Muchin Rosenman LLP

CFTC Proposes to Amend De Minimis Threshold for Swaps with Utility Providers

The Commodity Futures Trading Commission has proposed to amend the “special entity” de minimis exception from swap dealer designation to exclude certain swaps with public utility providers. The proposed regulations are...more

Katten Muchin Rosenman LLP

CFTC Grants Recordkeeping Relief for Certain SEF and DCM Members

The Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight of the Commodity Futures Trading Commission have issued relief from certain recordkeeping obligations for persons that are not...more

Eversheds Sutherland (US) LLP

CFTC Interprets “Swap” Definition In the Context of Longevity Risk Transfer

The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) recently addressed for the first time the CFTC’s definition of a “swap” as it applies to a specific insurance...more

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