News & Analysis as of

Registration Commodities Futures Trading Commission

Dechert LLP

Crypto Regulation: FIT21 and the U.S. Landscape

Dechert LLP on

More clearly define crypto asset regulatory boundaries for Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”), providing statutory definitions for “restricted digital assets” and...more

Pillsbury Winthrop Shaw Pittman LLP

Digital Commodities Consumer Protection Act to Provide Oversight of Digital Assets

The Act would expand the jurisdiction of the Commodity Futures Trading Commission to spot markets in digital commodities and would preempt state law. The timeline for the bill appears to be aggressive, with hearings on...more

A&O Shearman

US Commodity Futures Trading Commission Grants SEF and DCO Registration to LedgerX LLC

A&O Shearman on

The U.S. Commodity Futures Trading Commission issued an Order of Registration to LedgerX LLC (LedgerX) granting their request to register as a Swap Execution Facility (SEF). As a result, LedgerX becomes the 25th SEF...more

A&O Shearman

US Commodity Futures Trading Commission Issues Orders of Registration to Five Foreign Boards of Trade to Permit Trading by Direct...

A&O Shearman on

The CFTC issued Orders of Registration (Orders) to the following Foreign Boards of Trade (FBOT): (i) Eurex Deutschland; (ii) CME Europe Limited; (iii) ICE Futures Europe; (iv) The London Metal Exchange; and (v) London Stock...more

Katten Muchin Rosenman LLP

CFTC Approves Registration to 18 Swap Execution Facilities

The Commodity Futures Trading Commission has issued orders granting permanent registration to 18 swap execution facilities (SEFs) that had been operating under temporary registration status. The SEFs approved for registration...more

Katten Muchin Rosenman LLP

CFTC Grants DCO Registration to Nodal Clear, LLC

The Commodity Futures Trading Commission has granted registration to Nodal Clear, LLC as a derivatives clearing organization (DCO). Pursuant to the registration order, Nodal Clear may clear contracts executed on or through...more

Morrison & Foerster LLP

The SEC’s Registration Rules for Security-Based Swap Dealers

Early this month the U.S. Securities and Exchange Commission (“SEC”) released final rules (the “Registration Rules”) for the registration of security-based swap dealers (“SBSDs”). The Registration Rules, released more than...more

Katten Muchin Rosenman LLP

CFTC Requests Public Comment on a Petition from ASX Clear (Futures) Pty Limited for Exemption From Registration as a DCO

The Commodity Futures Trading Commission has requested public comment on a petition by ASX Clear (Futures) Pty Limited for exemption from registration as a derivatives clearing organization (DCO). ...more

Foley Hoag LLP

CFTC 4.13(a)(3) Annual Affirmations Due March 2

Foley Hoag LLP on

As a reminder, fund managers relying on the exemption from registration with the US Commodity Futures Trading Commission (the “CFTC”) set forth in Rule 4.13(a)(3), commonly referred to as the “de minimis exemption,” must...more

Katten Muchin Rosenman LLP

CFTC Grants Order of Registration to Tokyo Commodity Exchange

The Commodity Futures Trading Commission has issued an order granting the Tokyo Commodity Exchange––an exchange subject to the regulatory supervision of the Japanese Ministry of Economy, Trade and Industry and the Ministry of...more

Katten Muchin Rosenman LLP

CFTC Staff Grants No-Action Relief to Entities Operating Insurance-Linked Securities Issuers

On December 18, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a letter granting relief from commodity pool operator (CPO) registration to certain entities...more

Stinson - Corporate & Securities Law Blog

CFTC Grants Family Offices Relief From Registration as Commodity Trading Advisors

The CFTC previously granted family offices no-action relief from registration as commodity pool operators. That letter did not provide an exemption from registration as a commodity trading advisor. However, the CFTC has...more

K&L Gates LLP

CFTC Clarifies and Expands Relief Relating to Delegation of Commodity Pool Operator Responsibilities

K&L Gates LLP on

On October 15, 2014, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”) issued CFTC No-Action Letter No. 14-126 (“Letter 14-126”),...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Staff Allows Self Executing Delegation of CPO Functions

The staff of the Commodity Futures Trading Commission (CFTC) yesterday changed its position and no longer requires a no-action request for delegation of commodity pool operator (CPO) functions from persons that might...more

Eversheds Sutherland (US) LLP

NFA Issues Revised Forms CPO-PQR and CTA-PR

On June 5, the National Futures Association (NFA) announced the issuance of revised Forms CPO-PQR and CTA-PR. The NFA is the self-regulatory organization to which the Commodity Futures Trading Commission (CFTC) has delegated...more

Goodwin

CFTC Announces Streamlined Approach for Seeking Relief from Registration for Delegating Commodity Pool Operators

Goodwin on

The CFTC’s Division of Swap Dealer and Intermediary Oversight (the “Division”) announced a streamlined approach for requesting relief from the commodity pool operator (“CPO”) registration requirement for a CPO that delegates...more

Proskauer Rose LLP

CFTC Announces Streamlined CPO Delegation Process

Proskauer Rose LLP on

On May 12, 2014, the Commodity Futures Trading Commission (CFTC) issued a no-action relief letter adopting a streamlined approach for commodity pool operator (CPO) delegation. The letter clarifies the conditions under which a...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 12

In this issue: - Delaware Supreme Court Upholds Chancery Court Ruling that Applied Business Judgment Rule to Going Private Transaction with Controlling Stockholder - Amendments to Uniform Branch Office...more

Katten Muchin Rosenman LLP

CFTC Exempts MTFs from US Registration Requirements

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has issued CFTC Letter No. 14-15, which provides temporary no-action relief for (i) multilateral trading facilities (MTFs) overseen by regulators...more

Goodwin

NFA Provides Further Guidance on Bylaw 1101 Obligations of Members Who Do Business with CPOs/CTAs Relying on an Exemption or...

Goodwin on

The National Futures Association (the “NFA”) issued Notice I-14-06 providing guidance to its members regarding their Bylaw 1101 obligation to determine the CFTC registration and NFA membership status of persons with whom they...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 6

In this issue: - SEC Division of Corporation Finance Issues Guidance on Rule 506(c) Private Placements - SEC Issues No-action Relief Regarding Registration of M&A Brokers - CFTC Issues Guidance on New...more

Goodwin

NFA Issues Guidance on Annual Affirmation Requirement for Entities Operating Under An Exemption or Exclusion from CPO or CTA...

Goodwin on

The National Futures Association (the “NFA”) has issued guidance reminding market participants of CFTC regulations that require any person claiming an exemption or exclusion under CFTC Regulation 4.5, 4.13(a)(1), 4.13 (a)(2),...more

Goodwin

CFTC Proposes Rule to Require All Registered Introducing Brokers, Commodity Pool Operators, and Commodity Trading Advisors to be...

Goodwin on

The CFTC has proposed a rule that would require all registered introducing brokers (“IBs”), commodity pool operators (“CPOs”), and commodity trading advisors (“CTAs”) to be members of a registered futures association (“RFA”)....more

Katten Muchin Rosenman LLP

CFTC Proposes Rules to Require that IBs, CPOs and CTAs Become Members of a Registered Futures Association

The Commodity Futures Trading Commission has proposed rules requiring that all registered introducing brokers (IBs), commodity pool operators (CPOs) and commodity trading advisors (CTAs) become members of at least one...more

Eversheds Sutherland (US) LLP

CFTC Issues No-Action Relief and Interpretive Guidance Related to SEFs

As the date for compliance with swap execution facility (SEF) registration requirements approached, the Commodity Futures Trading Commission (the CFTC or Commission) issued a number of no-action letters and interpretive...more

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