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On April 30, 2024 the Commodity Futures Trading Commission (“CFTC” or the “Commission”) finalized amendments to its rules governing reporting requirements for large trader futures and options positions, the latest in a series...more
On November 7, 2023, the Division of Enforcement ("Division") of the United States Commodity Futures Trading Commission ("CFTC") released its annual report of the results of its enforcement efforts, announcing that it had...more
While the initial swap dealer enforcement actions brought by the Commodity Futures Trading Commission (CFTC) focused on swap data reporting failures, recent enforcement efforts have focused on compliance with business conduct...more
INTRODUCTION - The Commodity Futures Trading Commission (CFTC or Commission) recently voted 3–2 to approve a final rule (Final Rule) on the cross-border application of certain swap provisions under the Commodity Exchange Act...more
Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more
On July 24, 2017, the National Futures Association (“NFA”) adopted measures to streamline the process for registration of swap dealers pursuant to Section 4s of the Commodity Exchange Act. Previously, entities seeking to...more
On May 23, 2017, the Commodity Futures Trading Commission (“CFTC” or “Commission”) adopted amendments to its general regulations regarding the retention and production of regulatory records, which are set forth in CFTC...more
On July 6, 2016, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) fined Barclays Bank PLC (“Barclays”) $560,000 for inaccurate large trader reporting of swaps positions. This is the third and largest...more
Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more
TABLE OF CONTENTS I. Who Does the Dodd-Frank Act Impact? ...1 A. Major Swap Participants...1 1. Category 1: Substantial Position in Swap Categories ...1 2. Category 2: Substantial Counterparty Exposure...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