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Swap Dealers › Major Swap Participants › Reporting Requirements

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 -
Katten Muchin Rosenman LLP

The CFTC Adopts Amendments to Capital and Financial Reporting Requirements for Swap Dealers Largely Based on Prior Relief

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After adopting final rules in 2020, the Commodity Futures Trading Commission (CFTC) adopted amendments to the capital and financial reporting requirements for Swap Dealers (SDs), which were largely based on prior no-action...more

Orrick - Finance 20/20

CFTC Approves Final Swap Dealer Capital Rule

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On July 22, the Commodity Futures Trading Commission (CFTC) approved a final rule regarding new capital and financial reporting requirements for swap dealers and major swap participants that are not subject to supervision by...more

Orrick - Finance 20/20

CFTC Issues Advisory Regarding Chief Compliance Officer Annual Report Requirements

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On December 4, the CFTC issued an advisory (Staff Advisory 19-24) providing further guidance on certain requirements applicable to swap dealers, futures commission merchants and major swap participants (collectively,...more

WilmerHale

CFTC Proposes Additional Swap Data Reporting Requirements

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The Commodity Futures Trading Commission (CFTC) is proposing a significant, new reporting burden on swaps reporting parties and on swaps data repositories (SDRs). The proposal would impose new requirements on SDRs to verify...more

Morrison & Foerster LLP

CFTC Amends Chief Compliance Officer Duties and Annual Report Requirements

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On August 27, 2018, the Commodity Futures Trading Commission (“CFTC”) published final rules in the Federal Register amending its regulations regarding duties of chief compliance officers (“CCOs”) of swap dealers (“SD”), major...more

A&O Shearman

A Corporate End User’s Handbook for Dodd-Frank Derivatives Compliance

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The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), signed into law on July 21, 2010, was the largest overhaul of the U.S. derivatives market in history. While there are still a few parts of Dodd-Frank...more

Orrick - Finance 20/20

CFTC Staff Grants Time-Limited Extension of Swap Data Reporting Relief for Certain Swap Dealers and Major Swap Participants...

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On November 30, 2017, the U.S. Commodity Futures Trading Commission‘s (“CFTC“) Division of Market Oversight announced in a no-action letter that it had extended relief it provided certain CFTC-registered swap dealers (“SD“)...more

Morrison & Foerster LLP

CFTC Proposes to Amend Chief Compliance Officer Duties and Annual Report Requirements

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On May 3, 2017, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to its rules regarding the duties of Chief Compliance Officers (“CCOs”) for swap dealers...more

A&O Shearman

US Commodity Futures Trading Commission Approves Rule Amending Chief Compliance Officer Annual Report Timing for Certain...

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The US Commodity Futures Trading Commission announced its unanimous approval of a final rule amending CFTC regulation 3.3 to provide for a 90-day window after the end of an institution’s fiscal year for the filing of chief...more

Cadwalader, Wickersham & Taft LLP

CFTC Issues Fourth Penalty for Inaccurate Large Trader Reporting of Swaps

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On September 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) issued a fourth penalty for violations of its Swaps Large Trader Reporting (“Swaps LTR”) rule. This time, the penalty was...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

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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

Katten Muchin Rosenman LLP

CFTC Reminds SDs and MSPs of Swap Reporting Obligations

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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

Orrick - Finance 20/20

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

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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

Katten Muchin Rosenman LLP

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

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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

Katten Muchin Rosenman LLP

CFTC Further Extends Valuation Data Reporting Relief for SDs and MSPs

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The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has further extended no-action relief from the valuation data reporting requirements for cleared swaps under CFTC Regulation 45.4(b)(2)(ii)....more

Katten Muchin Rosenman LLP

CFTC Proposal Eases Trade Option Obligations for Non-SD/MSP Counterparties

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The Commodity Futures Trading Commission has proposed to amend part 32 of its regulations governing trade options to reduce the reporting requirements for counterparties that are not swap dealers or major swap participants...more

Orrick - Finance 20/20

CFTC Staff Issues No-Action Relief Regarding CCO Annual Report Timing Requirement

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On March 27, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to futures commission merchants, swap dealers and major swap participants from their obligation under...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume X, Issue 4

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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

Katten Muchin Rosenman LLP

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

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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

Katten Muchin Rosenman LLP

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

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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

Katten Muchin Rosenman LLP

SEC Proposes Recordkeeping and Reporting Rules for Security-based Swaps

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On April 17, the Securities and Exchange Commission proposed several new rules relating to security-based swaps. The rules deal with “recordkeeping, reporting, and notification requirements applicable to security-based swap...more

Perkins Coie

Financial Services Bulletin: Action At Federal Agencies

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Federal Agencies Issue Enhanced Supplementary Leverage Ratio Final Rule for Largest Banking Organizations and Propose Update to Supplementary Leverage Ratio Rule - On Tuesday, April 8, 2014, the Board of Governors of...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Expands Large Trader Reporting and Increases Customer Account Protection Requirements"

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The Commodity Futures Trading Commission (CFTC or Commission) recently adopted several rules to improve large trader reporting, facilitate segregation of customer swap margin and enhance customer protections for futures and...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - August 16, 2013

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In this issue: - SEC Issues Risk Alert on Options Trading Used to Evade Short-Sale Requirements - SEC Order Temporarily Exempting Certain Broker Dealers and Certain Transactions from the Recordkeeping and...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters

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Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more

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