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
While not unlimited, the relief is welcome for counterparties seeking to transition to risk-free rates for legacy swaps. The US Commodity Futures Trading Commission (CFTC) has issued no-action relief to help market...more
Introduction - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for floor traders to “encourage new liquidity providers to trade cleared swaps on registered venues without...more
In response to a request from the International Swaps and Derivatives Association, the Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight issued no-action relief that will permit swap...more
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
On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (“DSIO“) announced “conditional, time-limited no-action relief to a banking entity for not counting...more
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
On November 14, 2017, the U.S. Commodity Futures Trading Commission’s Division (“CFTC“) of Market Oversight extended time-limited no-action relief to swap execution facilities (“SEFs“) from certain requirements under the...more
On July 25, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) “issued a time-limited no-action letter that extends relief to swap dealers [] registered with the CFTC that are established under the laws of...more
CME and LCH Amend Rulebooks on Variation Margin - Market participants historically have characterized cleared derivatives as being "collateralized-to-market", treating variation margin transfers as daily collateral...more
The Commodity Futures Trading Commission (“CFTC” or “Commission”) has provided general exemptive relief to persons registered as commodity pool operators (“CPO”) under the Commodity Exchange Act that operate commodity pools...more
BROKER-DEALER - FINRA Issues Notice Regarding SEC’s Approval of New NMS Stock Recording and Reporting Requirements Rule - On August 8, the Financial Industry Regulatory Authority issued Regulatory Notice 16-28,...more
The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has issued CFTC Letter No. 16-10, which provides temporary no-action relief from certain trade option reporting requirements to market participants...more
On February 12, the U.S. Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight provided “no-action relief from registration” to a specific subset of individuals: “persons located outside...more
On September 17, 2015, the Commodity Futures Trading Commission (CFTC) issued an order filing and simultaneously settling charges against Australia and New Zealand Banking Group Ltd. (ANZ), an Australia-based firm that’s...more
On August 13, 2015, CFTC Division of Swap Dealer and Intermediary Oversight, Clearing and Risk, and Market Oversight extended a time-limited no-action relief to swap dealers registered with the CFTC that are established under...more
On August 13, the Division of Swap Dealer and Intermediary Oversight, Division of Clearing and Risk, and Division of Market Oversight of the Commodity Futures Trading Commission extended no-action relief from certain...more
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
The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has further extended no-action relief from the valuation data reporting requirements for cleared swaps under CFTC Regulation 45.4(b)(2)(ii)....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 June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from introducing broker (IB) and commodity trading advisor (CTA) registration to persons...more
The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued permanent no-action relief from the filing deadline for chief compliance officer (CCO) annual reports....more
The Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission has issued no-action relief to swap dealers (SDs) from certain business conduct standards in dealing with...more
On March 27, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to futures commission merchants, swap dealers and major swap participants from their obligation under...more
On March 31, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to provisionally registered swap dealers (SDs) from complying with certain specified regulations when...more