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Swap Dealers › Registration Requirement

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 -
Jones Day

Countdown to Security-Based Swap Registration and Compliance Deadlines

Jones Day on

Unless otherwise exempted, entities engaging in SBS dealing activity in the immediately preceding 12 months, as of the Counting Date and thereafter, must register as an SBS dealer if the SBS positions connected with its SBS...more

A&O Shearman

SEC Proposes Modifications to Cross-Border Application of Security-Based Swaps Regime

A&O Shearman on

The Securities and Exchange Commission (SEC) continues to take steps toward implementation of its security-based swap (SBS) dealer registration framework. A particular area of concern for market participants has been how the...more

Cadwalader, Wickersham & Taft LLP

Definitely Maybe? The SEC Returns to Security-Based Swap Dealer Regulation

Cadwalader, Wickersham & Taft LLP on

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) was signed into law eight years ago. ...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

Polsinelli on

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more

Hogan Lovells

U.S. federal regulators propose making permanent threshold for swap dealer registration potentially benefitting energy companies...

Hogan Lovells on

Pursuant to regulations promulgated under the Dodd-Frank Act, entities that make a market in swaps, hold themselves out as dealers in swaps or regularly enter into swaps for their own accounts are required to register as swap...more

A&O Shearman

Commodity Futures Trading Commission Proposes to Maintain $8 Billion Swap Dealer De Minimis Threshold and Approves Proposed...

A&O Shearman on

At the Commodity Futures Trading Commission's open meeting on June 4, 2018, the CFTC voted to propose rules that would permanently maintain the swap dealer de minimis registration threshold at $8 billion. The Commission voted...more

Orrick - Finance 20/20

CFTC Staff Issues Interpretive Guidance Clarifying Commodity Trading Advisor Registration Requirements Resulting from the European...

Orrick - Finance 20/20 on

On December 11, 2017, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight issued interpretative guidance providing that a futures commission merchant (“FCM“), swap dealer (“SD“), or...more

Orrick - Finance 20/20

Commission Approves an Order Regarding Swap Dealer Registration De Minimis Exception

Orrick - Finance 20/20 on

On October 13, 2016, the U.S. Commodity Futures Trading Commission extended until December 31, 2018, the $8 billion swap dealer registration de minimis threshold. Unless it is further modified, the threshold will become $3...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Proposes Rules to Count Cross-Border Swaps for Swap-Dealer Thresholds and Other Requirements"

Skadden, Arps, Slate, Meagher & Flom LLP on

The CFTC’s newly proposed rules on cross-border transactions address which swap activities affect swap-dealer thresholds and trigger transaction-level swap requirements. These are the latest in a series of CFTC rulemakings,...more

Stinson - Corporate & Securities Law Blog

CFTC Extends Swap Dealer De Minimis Phase-In Period

Stinson - Corporate & Securities Law Blog on

As has been rumored in recent weeks, the CFTC has adopted an order establishing December 31, 2018 as the swap dealer registration de minimis threshold phase-in termination date. With this approval, the de minimis threshold...more

Stinson - Corporate & Securities Law Blog

CFTC Chief Supports Extension of Swap Dealer De Minimis Exemption

Stinson - Corporate & Securities Law Blog on

Under current CFTC rules, market participants who exceed $8 billion in gross notional swap dealing activity over a twelve-month period are required to register with the CFTC as swap dealers during the phase-in period...more

Morrison & Foerster LLP

A step closer - The SEC still has some work to do to finalise its framework for SBS dealer registration but firms are already...

Morrison & Foerster LLP on

More than six years after the enactment of the Dodd-Frank Act, and more than three years after the US Commodity Futures Trading Commission (CTFC) required swap dealers to register in accordance with Title VII of that Act, it...more

Cadwalader, Wickersham & Taft LLP

CFTC Staff Issues Final Swap Dealer De Minimis Exception Report

Cadwalader, Wickersham & Taft LLP on

On August 15, 2016, Staff of the U.S. Commodity Futures Trading Commission (“CFTC”) published a final report regarding the de minimis exception from swap dealer registration (“Staff De Minimis Report”).  The Staff De Minimis...more

Eversheds Sutherland (US) LLP

Preliminary Report on the Swap Dealer De Minimis Exception

Eversheds Sutherland (US) LLP on

On November 18, the staff of the Commodity Futures Trading Commission (CFTC) issued a much anticipated report on the de minimis exception from the “swap dealer” definition, the Swap Dealer De Minimis Exception Preliminary...more

WilmerHale

Status of NFA's Section 4s Reviews and Swap Dealer Examinations

WilmerHale on

Beginning on December 31, 2012, swap dealers began filing applications for registration with the Commodity Futures Trading Commission (CFTC). As of October 2015, 104 entities are provisionally registered as swap dealers....more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Extends Registered Futures Association Membership Requirement to Introducing Brokers, Commodity Pool Operators and Commodity...

Skadden, Arps, Slate, Meagher & Flom LLP on

The Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule (“Final Rule”) that formally extends the existing registered futures association (“RFA”) membership requirement to registered introducing...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Finalizes Registration Rules for Security-Based Swap Entities"

Skadden, Arps, Slate, Meagher & Flom LLP on

On August 5, 2015, the Securities and Exchange Commission (SEC) adopted final registration rules for security-based (SB) swap dealers and major SB swap participants (collectively SBS Entities). Concurrently, the SEC also...more

Katten Muchin Rosenman LLP

SEC Adopts Registration Rules for Security-Based Swap Dealers and Major Security-Based Swap Participants

Katten Muchin Rosenman LLP on

On August 5, the Securities and Exchange Commission adopted new registration rules for security-based swap dealers and major security-based swap participants (SBS entities). In general, an SBS entity would register by filing...more

Orrick - Finance 20/20

SEC Adopts Registration Rules for Security-Based Swap Dealers and Major Security-Based Swap Participants

Orrick - Finance 20/20 on

On August 5, the SEC proposed new rules to provide a comprehensive, efficient process for security-based swap dealers and major security-based swap participants to register with the SEC. The new rules address all aspects of...more

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