On June 4, 2013, the Division of Clearing and Risk (the “Division”) of the US Commodity Futures Trading Commission (the “CFTC”) granted limited no-action relief from the mandatory clearing requirement for swaps entered into...more
On March 22, 2013, ISDA published the March 2013 Dodd-Frank Protocol (the “Protocol” or “Protocol 2.0”), which is designed to facilitate compliance with certain CFTC rules relating to clearing, portfolio reconciliation and...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
Some of the key changes to the swaps markets contemplated by the Dodd-Frank Act are starting to take effect. Some key upcoming deadlines affecting private investment funds are highlighted below.
On February 7, 2013, the US Department of Labor (DOL) issued Advisory Opinion 2013-01A (the “Advisory Opinion”), which provides guidance under the Employee Retirement Income Security Act of 1974 (ERISA) for employee benefit...more
The Department of Labor (DOL) recently issued a long-awaited advisory opinion (the Advisory Opinion) clarifying and confirming the ability of central counterparties (CCPs) and their clearing members (Clearing Members) to...more
New guidance defers to the Dodd-Frank/CFTC framework for regulating the swaps clearing process.
On February 7, the U.S. Department of Labor (DOL) issued an advisory opinion on the application of the ERISA fiduciary rules...more
Pursuant to Title VII of the Dodd-Frank Wall Street Reform and Customer Protection Act (Dodd-Frank), the Commodity Futures Trading Commission (CFTC) has adopted a number of final regulations that require swap dealers (SDs)...more
Central clearing of over-the-counter derivatives is a central pillar of the financial services reforms that are embodied in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The presumption...more
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