On April 24, the National Futures Association (NFA) issued a notice to members regarding amendments to NFA Compliance Rule 2-46. The amended rule modifies the NFA’s quarterly pool reporting requirements and extends related...more
On the brink of the compliance date for arguably one of the most burdensome requirements that end-users face under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Commodity Futures Trading...more
The enactment of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and its implementation by the Commodity Futures Trading Commission (“CFTC”) has ushered in a new era of...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
In this issue: - SEC and CFTC Adopt Joint Rules to Help Protect Investors from Identity Theft - CME Block Trade Advisories Clarify Nonpublic Information Restrictions - CFTC Staff Issues No-Action...more
The Securities and Exchange Commission (the “SEC”) has released several rounds of additional Frequently Asked Questions (“FAQs”) regarding Form PF, the private fund systemic risk reporting form promulgated by the SEC and the...more
On April 9, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight, responding to requests from multiple interested parties, issued a no-action letter (the No-Action Letter) extending the April...more
On April 1, the Commodity Futures Trading Commission approved a final rule that permits certain affiliates to elect not to clear a swap. To qualify for the clearing exemption, the counterparties’ financial statements must be...more
The CFTC has issued a no-action letter that effectively extends the dates for swap counterparties who are not swap dealers (SDs) or major swap participants (MSPs) to come into compliance with the agency’s reporting rules...more
On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk provided no-action relief (the No-Action Letter) from certain reporting requirements relating...more
On April 2, the CFTC issued a time limited no-action letter that extended the deadline for compliance with reporting for commodity pool operators of securitization vehicles from March 31 until June 30....more
All swap market participants, including commercial end-users, should be aware of the upcoming April 10 deadline for Commodity Futures Trading Commission (CFTC) swap reporting and recordkeeping requirements under Parts 43, 45...more
The CFTC has adopted a rule that exempts interaffiliate trades from the Dodd-Frank Act requirements for clearing. Barclays, JPMorgan Chase & Co., and other banks are among those exempt from the Dodd-Frank Act swap market...more
The CFTC has issued a final rule to exempt swaps between certain affiliated entities within a corporate group from the clearing requirement under the Commodity Exchange Act, or CEA, and CFTC regulations. ...more
In This Issue: *Financial Industry Developments - Agencies Issue Updated Leveraged Lending Guidance - CFTC No-Action Relief from Required Clearing for Some Partial Swap Novations and Terminations - FHFA...more
Since the beginning of 2013, the CFTC has required certain market participants to report their interest rate and credit index swap trades to a swap data repository, or SDR. CFTC Commissioner Scott D. O’Malia recently...more
Commodity Futures Trading Commission Regulation 3.3, which requires each futures commission merchant (FCM) to designate a chief compliance officer (CCO), will become effective on March 29, 2013 in respect of FCMs that are not...more
The Commodity Futures Trading Commission’s Division of Market Oversight issued an advisory to remind market participants that pursuant to Parts 43 and 45 of the CFTC’s regulations, swap dealers were required to begin...more
Please note the April 10, 2013, deadline to register and obtain a Legal Entity Identifier (LEI), described in the advisory recently released by the Commodity Futures Trading Commission (CFTC). LEI registration is...more
The CFTC's Dodd-Frank swap reporting and recordkeeping requirements become mandatory on April 10, 2013, for all persons and companies engaging in swaps. These requirements include the agency's swap data reporting and...more
In This Issue: *Financial Industry Developments - CFTC Announces the Start of Mandatory Clearing - CFTC Reminds Market Participants of Swap Data Reporting Requirements - Rating Agency Developments...more
On March 8, the CFTC issued an Advisory reminding market participants that swap dealers were required to begin reporting data regarding equity, foreign exchange, and other commodity swaps, under Parts 43 and 45 of the CFTC’s...more
In this issue: - Mary Jo White, Nominee for Chair of the SEC, Appears Before Senate Banking Committee - SEC Proposes Rules Regarding Technology Systems - FINRA Amends Rules to Address Extraordinary Market...more
On Wednesday, March 6, 2013, the Commodity Futures Trading Commission (the "CFTC") approved the request from the Chicago Mercantile Exchange Inc. (the "CME") for the CME to adopt new Chapter 10 and new Rule 1001 in the CME’s...more
On March 6, the Commodity Futures Trading Commission approved the Chicago Mercantile Exchange Inc.’s (CME) request to adopt CME Rule 1001. CME Rule 1001 addresses the CME’s obligation, in its capacity as a derivatives...more
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