Jill Sommers Reflects on the CFTC, Dodd-Frank, and Her Future
Regulation 2013: Dodd-Frank Position Limits, CFTC Reuthorization, Regulatory Harmonization
INTRODUCTION - The Commodity Futures Trading Commission (CFTC) recently voted 3–2, along party lines, to approve a final rule (Final Rule) regarding position limits for certain futures contracts and economically equivalent...more
On October 15, 2020, the Commodity Futures Trading Commission (CFTC) voted 3-2 to adopt new rules on speculative position limits (the Final Rule). The Final Rule will become effective 60 days after publication in the Federal...more
On October 15, the Commodity Futures Trading Commission adopted new rules on position limits. The new rules mark an important step forward in a decade-long journey to enact one of the remaining key provisions of Title VII of...more
On January 30, 2020, the Commodity Futures Trading Commission (CFTC or Commission) voted 3-2 to issue a proposed rulemaking on speculative position limits (the Proposal). The Proposal would apply spot month-only federal...more
Will the fourth time be the charm? This week, the Commodity Futures Trading Commission will try for the fourth time since 2011 to revise its speculative position limits rules. Details have not been made public, but Heath...more
In the almost six years since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the US Commodity Futures Trading Commission (CFTC) has, in large part, finalized its rulemakings...more
Significant amendments to the CFTC’s large trader reporting program will apply as of August 15, 2014. The U.S. Commodity Futures Trading Commission (CFTC) has seemingly increased the number of Form 40/40S requests it...more
In our recent post, “CFTC Forward vs. Trade Option: LDCs Still Struggle as Trade Option Reporting Deadline Looms,” we discussed the unintended impact of the Dodd-Frank Wall Street Reform and Consumer Protection Act...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank” or the “Act”) authorizes the Commodity Futures Trading Commission (“CFTC”) to comprehensively regulate energy trading activities. Dodd-Frank is...more
The US Commodity Futures Trading Commission (CFTC), on November 5, 2013, re- proposed a rulemaking (the Re-Proposed Rule) that would establish specific limits on speculative positions in 28 physical commodity futures and...more
On November 5, 2013, the Commodity Futures Trading Commission (“CFTC” or “Commission”) proposed new speculative position limits. The proposal (“New Proposal”) would establish spot-month and non-spot-month limits for 28 core...more
Today, the CFTC Division of Market Oversight published a response to frequently asked questions regarding commodity options, including reporting obligations with respect to trade options. The response clarified a few...more
The United States District Court for the District of Columbia granted summary judgment for plaintiffs International Swaps and Derivatives Association (ISDA) and Securities Industry and Financial Markets Association (SIFMA),...more
NYSE and Nasdaq Propose Changes to Compensation Committee Independence Rules. On Tuesday, September 25, 2012, the New York Stock Exchange ("NYSE") and the NASDAQ Stock Marker ("Nasdaq") filed proposed amendments to...more
In This Issue: Excerpt from Year-End Tax Planning Steps for Private Equity The last time the Bush tax cuts were set to expire at the end of 2010, we saw numerous clients scrambling to execute end-of-the-year...more
On September 28, 2012, in the case of International Swaps and Derivatives Association v. U.S. Commodity Futures Trading Commission, the District Court for the District of Columbia (the "Court") ruled that the Commodity...more
On September 28, 2012, Judge Robert Wilkins of the U.S. District Court for the District of Columbia granted the summary judgment motion of the International Swaps and Derivatives Association and Securities Industry and...more
Last Friday, September 28th, the U.S. Federal District Court in Washington, D.C. (“Court”) struck down the commodity speculative position limit rulemaking that the U.S. Commodity Futures Trading Commission (“CFTC”) had...more
The CFTC’s final rule on position limits with respect to derivative contracts in 28 different physical commodities has been vacated and remanded back to the agency. Spot month limits under the rule had been set to go into...more
Discussion Topics •General Overview of the Dodd-Frank Act •Title VII of the Dodd Frank Act: Impact on OTC Derivatives and Energy Trading •Definitions and applicability •Mandatory clearing •Registration requirements ...more