On December 10, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity...more
In a letter dated March 29, 2013 (the “March 29 Letter”), the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”), extended by three months, but subject...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
Recent changes to the commodity pool regulations under the Commodity Exchange Act (the “CEA”) may subject certain securitization transactions and their managers to regulation by the Commodity Futures Trading Commission (the...more
On December 7, the CFTC provided guidance to securitization vehicles on whether they may be excluded from the definition of commodity pool....more
On Friday, December 7, 2012, the U.S. Commodity Futures Trading Commission (CFTC), through its Division of Swap Dealer and Intermediary Oversight (Division), issued a letter which provides broad relief for certain segments of...more
In two interpretive letters issued on October 11, 2012 (collectively, the “Interpretive Letters”), the Division of Swap Dealers and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the...more
Last Thursday, the U.S. Commodity Futures Trading Commission (“CFTC”) responded to ASF’s and SIFMA’s requests for relief from the new CFTC rules which implemented certain Dodd-Frank amendments that brought swaps within the...more
Perhaps one of the most important questions since the Dodd-Frank Act is “What is a commodity pool”? Close behind is “Who is a commodity pool operator”? The CFTC has begun to shed light on these questions by issuance of...more
Dear Clients and Friends: In October, federal agencies proposed two new sets of regulations under the Dodd-Frank Act. The proposals — to implement the Volcker Rule and to create standards to designate certain nonbanks...more