Swap Dealers

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
News & Analysis as of

Bridging the Week - March 2017 #3

CFTC Chairman Nominee Warns of Tough Love to Come: KISS But Also Aggressive and Assertive Enforcement: In a speech last week before an assembly of industry executives at FIA’s annual Boca Raton conference, J. Christopher...more

US and EU Regulators Provide Relief for Compliance with Variation Margin Requirements

The CFTC, the Federal Reserve Board and the Office of the Comptroller of the Currency have taken action to extend the period during which Swap Dealers can comply with the requirement to post and collect variation margin under...more

US Commodity Futures Trading Commission Issues Time-Limited No-Action Transition for March 1, 2017 Compliance Date for Variation...

US Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a time-limited no-action letter (CFTC staff letter 17-11) which provides that, from March 1, 2017 to September 1,...more

The Federal Reserve and OCC Guidance Regarding Initial Examinations for Compliance with Variation Margin Rules for Non-Cleared...

Last week the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and the Office of the Comptroller of the Currency (the “OCC” and, collectively with the Federal Reserve, the “Banking Agencies”) released...more

Update: Prudential Regulators Delay Compliance Deadline for New Swap Margin Rules

If you have been following our alerts on the pending deadlines (and the delays of these deadlines by certain regulators) of the new swap variation margin rules (New Swap Margin Rules) that were due to go into effect on March...more

Bridging the Week - February 2017 #3

CFTC Postpones Swap Dealer Compliance Date for OTC Swaps Variation Margin Requirements; Other Regulators Likely to Exercise Forbearance: On February 13, the Commodity Futures Trading Commission’s Division of Swap Dealer and...more

CFTC’s Division of Swap Dealer and Intermediary Oversight Issues Time-Limited No-Action Transition for March 1, 2017 Compliance...

On February 13, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) announced that, between March 1, 2017 and September 1, 2017, it would “not recommend an enforcement action against a swap dealer (SD) for...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

Swap Dealer Banks Win Six Month Phase-In for Variation Margin Requirements for Most Counterparties

U.S. swap dealer banks received much needed breathing room, but not complete relief from the March 1, 2017 variation margin (VM) deadline for swaps and security-based swaps. On February 23, 2017, the Federal Reserve Board...more

CFTC Implements Phase-in Period for New Variation Margin Requirements

On February 13, 2017, the U.S. Commodity Futures Trading Commission (CFTC) issued time-limited no-action relief providing a six-month grace period for certain swap dealers to come into compliance with the variation margin...more

Update: CFTC Delays Compliance Deadline for New Swap Margin Rules

Although the letter technically does not delay the effective date of March 1, 2017, from the perspective of the buy side, the letter functions as a “grace period,” and the compliance date has been moved to September 1, 2017....more

Documentation for the New Swap Margin Rules and Thoughts for the Buy Side and End Users

Because of the implementation of new regulatory requirements relating to both variation and initial margin for swaps, swap documentation for many market participants is about to become much more complicated....more

U.S. CFTC Enforcement Considerations for 2017

Change is in the air and the political landscape may significantly affect the U.S. Commodity Futures Trading Commission’s enforcement agenda. Last month, Commissioner J. Christopher Giancarlo rose to the position of Acting...more

CFTC Issues No-Action Relief for Swap Dealers Complying with the EU Margin Rules

The CFTC has issued no-action relief for Swap Dealers that are subject to, and in compliance with, the EU margin rules but fail to comply with certain provisions of the CFTC’s margin rules for the period from February 4, 2017...more

Insurance Companies Need to Prepare for Swap Margin Rules in Effect on March 1, 2017

March 1, 2017, is the scheduled implementation date applicable for all insurance companies for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules. Although the...more

CFTC Permits Unaudited Financial Statements Upon Liquidation of a Series of a Pool That is Also a Registered Investment Company

The Commodity Futures Trading Commission (“CFTC” or “Commission”) has provided general exemptive relief to persons registered as commodity pool operators (“CPO”) under the Commodity Exchange Act that operate commodity pools...more

Will the CFTC Postpone the March 1, 2017 Variation Margin Deadline?

Derivatives traders and lawyers are focused on March 1. Not for any basketball tournaments, but for the variation margin (VM) big bang. From March 1, 2017, swap dealers and financial end-users will be required to exchange VM...more

US House of Representatives Passes Bill Re-Authorizing the US Commodity Futures Trading Commission

The US House of Representatives passed H.R. 238, the Commodity End-User Relief Act, a bipartisan bill to reauthorize the US CFTC...more

Unfinished Business: SEC Chair Details Rules Ready to Go

In a letter dated December 12, 2016, to the Chair of the Senate Committee on Banking Housing and Urban Affairs, SEC Chair Mary Jo White took issue with a request to defer consideration of new rulemaking during the...more

US Commodity Futures Trading Commission Proposes Rule Establishing Minimum Capital Requirements for Swap Dealers

The CFTC issued a proposed rule establishing minimum capital requirements for Swap Dealers and Major Swap Participants. As required by section 731 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the rules...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - CTFC Approves Re-Proposal of Position Limits Regulation - On December 5, 2016, the U.S. Commodity Futures Trading Commission ("CFTC") unanimously approved to re-propose rules that...more

CFTC Approves Minimal Capital Requirements for Swap Dealers and Major Swap Participants

On December 2, 2016, the U.S. Commodity Futures Trading Commission (CFTC) unanimously approved proposed rules that establish minimum capital requirements for swap dealers and major swap participants. The proposed rules set...more

SEC Chair White Refuses To Delay New Rules

According to Fortune, outgoing Securities and Exchange Commission Chair Mary Jo White is refusing to delay adoption of new rules and regulations. Senate Republicans–in particular the Senate Banking Committee’s top two...more

Bridging the Week - December 2016

CFTC Re-Proposes Capital Rules for Swap Dealers: The Commodity Futures Trading Commission re-proposed minimum capital requirements for swap dealers and major swap participants that are not subject to prudential...more

"Non-Cleared Swap Variation Margin Requirements to Spark Credit Support Annex Amendments for Financial End Users"

On March 1, 2017, new rules adopted by U.S. Prudential Regulators and the Commodity Futures Trading Commission (CFTC) will require registered swap dealers to post and collect daily variation margin for over-the-counter,...more

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