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

NFA Notifies SDs and MSPs of Annual Questionnaire Requirements

Beginning April 1, National Futures Association (NFA) will require its member swap dealers (SDs) and major swap participants (MSPs) to complete the SD-MSP Annual Questionnaire as part of its annual membership renewal process....more

NFA Announces New Filing Process for Swap Dealer and Major Swap Participant CCO Reports

On January 23, the National Futures Association (NFA) issued a notice informing its members that the annual reports required by NFA rules to be submitted by the chief compliance officer (CCO) of a swap dealer (SD) or major...more

Corporate and Financial Weekly Digest - Volume X, Issue 4

In this issue: - SEC Division of Corporation Finance Issues New C&DI Related to Resales Under Regulation S - SEC Announces Proxy Voting Roundtable - CFTC Staff Issues No-Action Relief From Certain...more

House Bill Seeks to Limit Certain Provisions of Dodd-Frank

On Jan. 14, 2015, the effort to repeal or amend certain provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) continued in the heavily Republican House of Representatives with the...more

CFTC Staff Issues No-Action Relief Extending the Deadline for Certain CCO Annual Reports

On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter that extends the deadline for submitting the annual report that must be...more

CFTC Staff Issues Guidance Regarding Chief Compliance Officer Annual Reports

On December 22, 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued guidance regarding the annual reports that must be filed by the chief compliance officer (CCO)...more

Congress Exempts Non-Financial End-Users, Their Agents and Certain Cooperatives From Non-Cleared Swap Margin Requirements in...

On January 8, 2015, the U.S. Senate approved legislation, by a 93-4 vote, to reauthorize the Terrorism Risk Insurance Act (“TRIA”). The legislation, dubbed the Terrorism Risk Insurance Program Reauthorization Act of 2015 (the...more

Swap Dealers Will Face Significant Challenges from Reproposed Margin Rules for Uncleared Swaps

Dealers and major industry participants may be subject to new margin requirements beginning as early as December 1, 2015. Regulators are expected to finalize rules regarding margin requirements for uncleared swaps...more

Between Bridges: In Time for Christmas, CFTC Staff Gives FCMs, SDs and MSPs Gift of Time Extension to File CCO Annual Report;...

Just prior to Christmas 2014, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight issued no-action relief extending the deadline by when chief compliance officer annual reports must...more

Prudential Regulators and CFTC Re-Propose Margin Requirement Rules for Uncleared Swaps

The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing Finance Agency...more

Financial Regulatory Developments Focus - October 2014 #4

In this issue: - Derivatives - Compensation - Shadow Banking - Bank Prudential Regulation & Regulatory Capital - Recovery & Resolution - Financial Market Infrastructure -...more

OCC Proposes Rule on Margin and Capital Requirements for Covered Swap Entities

October 6, the OCC released a notice of proposed rulemaking to establish minimum requirements for the exchange of initial and variation margin between registered swap dealers, major swap participants, security-based swap...more

CFTC and NFA Require SD and MSP Risk Exposure Reports to Be Submitted Through WinJammer

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) and National Futures Association (NFA) announced that, effective September 30, swap dealers (SDs) and major swap...more

Regulators Re-Propose Minimum Margin Requirements for Uncleared Swaps

U.S. Federal banking regulators (the “Prudential Regulators”) recently re-proposed rules providing for minimum margin requirements for uncleared swaps and security-based swaps executed by swap dealers, security-based swap...more

CFTC Proposes Margin Requirements for Uncleared Swaps

On September 17, the CFTC approved a proposed rule addressing margin requirements for uncleared swaps entered into by swap dealers or major swap participants that are not subject to regulation by the Federal Reserve Board,...more

Regulators Publish Re-proposed Margin Requirements for Uncleared Swaps

On September 3, 2014, the Board of Governors of the Federal Reserve System (the Board) jointly adopted, with certain federal banking regulators, re-proposed rules that will require registered swap dealers, security-based swap...more

Bridging the Week - September 2014 #2

CFTC Proposes Margin Rules for Uncleared Swaps and Approves Special Treatment for Operations-Related Swaps With Certain Government-Owned Natural Gas and Electric Utilities - A few weeks after the Federal Reserve Bank...more

CFTC Proposes Margin Rules for Uncleared Swaps

On September 17, the Commodity Futures Trading Commission issued proposed rules that would impose margin requirements on certain market participants with respect to their transactions in uncleared swaps. ...more

SEC Proposes New Rule on Communications Involving Security-Based Swaps

On September 8, the SEC proposed a new rule that certain communications involving security-based swaps that may be purchased only by eligible contract participants will not be deemed for purposes of Section 5 of the...more

Prudential Regulators and CFTC Re-Propose Margin Requirements for Non-Cleared Swaps

Federal banking regulators (the Prudential Regulators) have re-proposed regulations to require certain dealers and major participants in the swap and security-based swap markets to collect initial and variation margin for...more

CFTC Votes to Re-Propose Margin Requirements for Uncleared Swaps

On September 17, 2014, the Commodity Futures Trading Commission (“CFTC”) voted to re-propose rules to impose initial and variation margin requirements on uncleared swaps entered into by swap dealers and major swap...more

Financial Regulatory Developments Focus - September 2014 #3

In this issue: - Derivatives - Consumer Protection - Enforcement - People - Events - Excerpt from Derivatives: CFTC Issues No-Action Relief for Qualifying Swaps Trading...more

Bank Regulators Propose Relaxed Margin Requirements for Corporate End Users of Uncleared Swaps

Five federal agencies have taken a second stab at a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap dealers, and major security-based swap participants as...more

Federal Agencies Seek Comment on Swap Margin Requirements

On September 3, the Fed, the Farm Credit Administration, the FDIC, the FHFA, and the OCC sought comment on a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap...more

Harmony or Dissonance: The CFTC’s and SEC’s Cross-Border Rules

Recently, the SEC issued final rules addressing, among other things, the applicability of the security-based swap dealer (“SBSD”) and major security-based swap participant (“MSBSP”) definitions to cross-border security-based...more

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