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The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), signed into law on July 21, 2010, was the largest overhaul of the U.S. derivatives market in history. While there are still a few parts of Dodd-Frank...more
The CFTC approved a final rule today that removes trade option* reporting and recordkeeping requirements applicable to non-swap dealer/major swap participant counterparties (“Non-SD/MSPs” or “end users” for purposes of this...more
On May 2, 2014, the Securities and Exchange Commission (SEC)published in the Federal Register proposed regulations1 that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street...more
The SEC issued a release proposing recordkeeping, reporting, and notification requirements for security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”). Although described as seeking to...more
On April 17, the Securities and Exchange Commission proposed several new rules relating to security-based swaps. The rules deal with “recordkeeping, reporting, and notification requirements applicable to security-based swap...more
Federal Agencies Issue Enhanced Supplementary Leverage Ratio Final Rule for Largest Banking Organizations and Propose Update to Supplementary Leverage Ratio Rule - On Tuesday, April 8, 2014, the Board of Governors of...more
Following up on its January 21, 2014, formation of an interdivisional staff working group (Working Group) to review its swap data reporting and other provisions of Part 45 of its regulations, on March 19, 2014, the Commodity...more
In this issue: - SEC Issues Risk Alert on Options Trading Used to Evade Short-Sale Requirements - SEC Order Temporarily Exempting Certain Broker Dealers and Certain Transactions from the Recordkeeping and...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
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