Swap Dealers Major Swap Participants

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

Key Differences Between CFTC and SEC Final Business Conduct Standards and Related Cross-Border Requirements

The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more

CFTC Releases Its Final Staff Report on the Swap Dealer De Minimis Exception

Last month the Commodity Futures Trading Commission (“CFTC”) released the final report of its staff (the “Staff”) on the de minimis exception to the CFTC’s definition of “swap dealer” (the “Final Report”). That exception,...more

CFTC Issues Final Rules on Cross-Border Uncleared Swap Margin Requirements

The CFTC has combined an entity-level approach with a transaction-level approach in its final cross-border uncleared swap margin requirements. Introduction - On December 16, 2015, the Commodity Futures Trading...more

CFTC Finalizes Cross-Border Margin Rules for Uncleared Swaps

On May 24, 2016, the Commodity Futures Trading Commission (CFTC) adopted final rules (cross-border margin rules) that specify how its recently issued uncleared margin rules apply to cross-border transactions. Chairman Timothy...more

CFTC Amends Swap Portfolio Reconciliation Requirement

On May 2, 2016, the U.S. Commodity Futures Trading Commission approved a final rule to amend the swap portfolio reconciliation requirement. Under CFTC Regulation 23.500(i), swap dealers and major swap participants were...more

US Commodity Futures Trading Commission Approves Final Rule on Amendments to the Swap Portfolio Reconciliation Requirement

The Commodity Futures Trading Commission approved a final rule to amend a requirement found in CFTC Regulation 23.500(i) that swap dealers and major swap participants exchange the terms of swaps with their counterparties for...more

Financial Services Weekly News - April 2016 #3

Regulatory Developments - FHFA Announces Principal Reduction Program for Struggling Underwater Homeowners - On April 14, the Federal Housing Finance Agency (FHFA) announced a new Principal Reduction Modification...more

CFTC Proposed Guidance on Gas and Capacity Contracts Further Reduces Dodd-Frank Swap Burdens on End-Users

On April 4, 2016, the Commodity Futures Trading Commission (CFTC) issued proposed guidance that two products – common in competitive wholesale electric and natural gas markets – would not be considered swaps under the...more

US Commodity Futures Trading Commission Approves Final Rule to Amend the Trade Option Exemption

The Commodity Futures Trading Commission approved a final rule that removes certain reporting and recordkeeping requirements for trade option counterparties that are neither swap dealers nor major swap participants...more

"CFTC Eliminates End-User Trade Option Reporting Requirements and Addresses Applicability of Position Limits"

The Commodity Futures Trading Commission (CFTC or Commission) adopted a final rule effective March 21, 2016, that eliminates the reporting and recordkeeping requirements under the CFTC’s existing trade option exemption for...more

Bridging the Week - March 2016 #3

Industry Comments to Regulation AT Argue CFTC Proposed Rules Too Prescriptive; Registration and Source Code Requirements Particularly Objectionable - After declining multiple requests to extend the comment period that...more

CFTC Approves Final Rule Eliminating Certain Reporting and Recordkeeping Requirements for Trade Option End-Users

On March 16, the Commodity Futures Trading Commission unanimously approved a final rule removing reporting and recordkeeping requirements for trade option counterparties that are neither swap dealers nor major swap...more

NFA To Review Initial Margin Models for SDs and MSPs

National Futures Association (NFA) has issued a notice reminding its swap dealer (SD) and major swap participant (MSP) members of their obligations under the new uncleared swap margin requirements adopted by the Commodity...more

Corporate and Financial Weekly Digest - Volume XI, Issue 10

BROKER-DEALER - SEC Announces Creation of Office of Risk and Strategy - On March 8, the Securities and Exchange Commission announced the creation of the Office of Risk and Strategy (ORS) within the SEC’s Office of...more

Mandatory Margin Posting Regulations Coming Soon for Uncleared Swaps

U.S. bank regulators recently adopted final rules establishing initial and variation margin requirements for uncleared swaps (Final Margin Rules). These rules apply to regulated entities such as banks and subsidiaries of bank...more

CFTC Grants Relief for End Users from Trade Option Filing Requirements

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has issued CFTC Letter No. 16-10, which provides temporary no-action relief from certain trade option reporting requirements to market participants...more

NFA Issues Notice Regarding Swap Valuation Dispute Notices

On February 2, National Futures Association (NFA) issued Notice I-16-07, which implements an order previously issued by the Commodity Futures Trading Commission authorizing NFA to receive notices of swap valuation disputes...more

CFTC Issues Order Delegating to the NFA Certain Functions Related to Notices of Swap Valuation Disputes

The Commodity Futures Trading Commission has authorized the National Futures Association (NFA) to receive, review, maintain and serve as the official custodian of records for notices of swap valuation disputes in excess of US...more

NFA Revises SD and MSP 4s Review Process

National Futures Association (NFA) has revised its review process for swap dealer (SD) and major swap participant (MSP) applications under Section 4s of the Commodity Exchange Act. Effective immediately, SDs and MSPs are no...more

CFTC Reminds SDs and MSPs of Swap Reporting Obligations

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission has issued an advisory to remind swap dealers (SDs) and major swap participants (MSPs) of their swap data reporting...more

CFTC Adopts Final Margin Rules for Swap Dealers

On December 16, the Commodity Futures Trading Commission adopted final rules that set margin requirements for swap dealers and major participants (collectively, Swap Entities) regulated by the CFTC with respect to swaps that...more

CFTC Approves Final Rule on Margin Requirements for Uncleared Swaps

The U.S. Commodity Futures Trading Commission (CFTC) approved on December 16 final rules (Final Rules) on margin requirements for over-the-counter uncleared swaps entered into by CFTC-registered swap dealers (SDs) and major...more

NFA Issues Notice on the Inclusion of Legal Entity Identifiers in the Swap Dealer/Major Swap

The National Futures Association (NFA) has issued Notice I-15-28, which discusses the legal entity identifiers (LEIs) that are now being used in the NFA’s swap dealer/major swap participant registry (SD/MSP Registry). The...more

U.S. Swap Dealers and Non-U.S. Major Swap Participants Under SDR Reporting Rules

On November 9, the U.S. Commodity Futures Trading Commission’s (the “CFTC“) Division of Market Oversight issued a time-limited no-action letter extending the relief provided in CFTC Letter No. 14-141. The relief applies to...more

CFTC Extends Swap Data Reporting Relief to Certain Non-US SDs and MSPs

The Division of Market Oversight of the Commodity Futures Trading Commission has extended relief from swap data reporting obligations for swap dealers (SDs) and major swap participants (MSPs) that are non-US persons...more

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