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Swap Dealers Bona Fide Hedging

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 -
Akin Gump Strauss Hauer & Feld LLP

CFTC Re-Proposes Position Limits for Certain Commodity Futures Contracts and Economically Equivalent Swaps

- Federal spot month limits would expand to cover 25 physical commodity futures, as well as certain “look alike” contracts and OTC swaps on the same underlying commodity. - Limits generally would be set at higher levels...more

Bracewell LLP

The CFTC Proposes a New Approach to Federal Position Limits -- Will This One Stick?

Bracewell LLP on

At its open meeting held on January 30, 2020, the Commodity Futures Trading Commission (“CFTC” or “the Commission”) approved a proposed rulemaking to institute federal position limits in an effort to prevent excessive...more

Katten Muchin Rosenman LLP

CFTC Issues Guidance in Conjunction with "Swap" Definition Effective Date

In light of the numerous regulatory changes triggered by the definition of “swap” taking effect on October 12, Commodity Futures Trading Commission staff released a series of no-action letters and interpretations late last...more

Orrick - Finance 20/20

CFTC No-Action Letters

Orrick - Finance 20/20 on

On October 12, the CFTC released a number of no-action letters and interpretive guidance addressing: - Swap calculation by certain foreign entities for purposes of the swap dealer and major swap participant...more

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