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Swap Dealers › Swaps › 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 -
Orrick, Herrington & Sutcliffe LLP

CFTC orders bank to pay $5M for swap reporting violations

Orrick, Herrington & Sutcliffe LLP on

On August 26, the CFTC issued an order against a bank for allegedly failing to correctly report millions of swap transactions to a registered swap data repository, in violation of a prior CFTC order, and for failing to...more

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

Cadwalader, Wickersham & Taft LLP

CFTC Finalizes Rule Regarding LIBOR Transition Clearing Requirement Determination for Certain Interest Rate Swaps

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On August 12, the Commodity Futures Trading Commission (“CFTC”) issued a final rule amending its Regulation 50.4(a) clearing requirements for swaps. The latest in a series of rulemaking that is supportive of the...more

Cadwalader, Wickersham & Taft LLP

CFTC’s Swap Reporting Advisory

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Accurate and timely reporting of swap data is the cornerstone of swap regulation. The CFTC had promulgated its swap reporting rules in 2012, and were after 2012 among the first rules implementing the Dodd-Frank Act to...more

Morgan Lewis

CFTC Amends Real-Time Swap Public Reporting Requirements

Morgan Lewis on

The Commodity Futures Trading Commission (CFTC) has unanimously approved amendments to the real-time swap reporting rules in Part 43 of the CFTC’s regulations by, among other things, clarifying the applicability of the rules...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

Stoel Rives - Renewable + Law

CFTC Proposed Rule Benefits Certain Financially-Settled Offtake Arrangements

Stoel Rives - Renewable + Law on

On February 20, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved a proposed rule that would revise certain reporting requirements for financially-settled offtake contracts that qualify as “swaps”...more

WilmerHale

The SEC's Security-Based Swap Recordkeeping and Reporting Rules

WilmerHale on

On September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major...more

Orrick - Finance 20/20

SEC Adopts New Rules and Amendments Under Title VII of Dodd-Frank

Orrick - Finance 20/20 on

On September 19, the SEC adopted new rules and amendments under Title VII of the Dodd-Frank Act establishing recordkeeping and reporting requirements for security-based swap dealers and major security-based swap participants,...more

WilmerHale

CFTC Proposes Additional Swap Data Reporting Requirements

WilmerHale on

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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes Sweeping Swap Reporting Amendments Aimed at Improving Data Accuracy and Completeness

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On April 25, 2019, the Commodity Futures Trading Commission (CFTC or Commission) published for public comment proposed amendments to the rules governing swap data repositories (SDRs) and reporting obligations of swap market...more

Morrison & Foerster LLP

CFTC Chairman Issues White Paper Outlining Agenda for Changes to Swaps Regulation

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On April 26, 2018, J. Christopher Giancarlo, Chairman of the Commodity Futures Trading Commission (“CFTC” or “Commission”) and Bruce Tuckman, the CFTC’s Chief Economist, issued a white paper outlining changes to swaps...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

Stinson - Corporate & Securities Law Blog

CFTC Proposes Amendments to Chief Compliance Officer Duties and Annual Reports

Stinson - Corporate & Securities Law Blog on

The CFTC is proposing to amend its regulations regarding certain duties of chief compliance officers, or CCOs, of swap dealers, major swap participants and futures commission merchants, which are referred to as registrants....more

Cadwalader, Wickersham & Taft LLP

[Webinar] Not Your Grandmother's Form 40 - Nov. 22nd, 2:00 pm EDT

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Tuesday, November 22, 20162:00 PM – 3:00 PM EDT A common tool that the Commodity Futures Trading Commission (“CFTC” or the “Commission”) relies upon to conduct market surveillance, including monitoring compliance with...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

Orrick, Herrington & Sutcliffe LLP

Derivatives in Review - July 2016

Orrick, Herrington & Sutcliffe LLP on

An Overview of Proposed Regulation AT - Orrick attorneys authored an overview of Regulation Automated Trading (known as "Regulation AT") proposed by the Commodity Futures Trading Commission ("CFTC") in the May/June 2016...more

Orrick, Herrington & Sutcliffe LLP

SEC Amends Rules on Security-Based Swap Reporting

Orrick, Herrington & Sutcliffe LLP on

On July 13, 2016, the Securities Exchange Commission (“SEC”) approved certain amendments and guidance to the rules governing the reporting and public dissemination of security-based swaps (“SBS”), known as “Regulation SBSR,”...more

Cadwalader, Wickersham & Taft LLP

CFTC Issues $560,000 Penalty for Inaccurate Large Trader Reporting of Swaps

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On July 6, 2016, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) fined Barclays Bank PLC (“Barclays”) $560,000 for inaccurate large trader reporting of swaps positions. This is the third and largest...more

Orrick, Herrington & Sutcliffe LLP

Derivatives in Review - April 2016

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Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more

Goodwin

Financial Services Weekly News - November 2015

Goodwin on

Regulatory Developments - Client Alert: SEC Issues New Guidance on Excluding Shareholder Proposals under Rule 14a-8: Goodwin Procter’s Capital Markets practice has released a client alert on the SEC’s Division of...more

McGuireWoods LLP

CFTC Zeros in on Large Trader Reporting

McGuireWoods LLP on

On September 17, 2015, the Commodity Futures Trading Commission (CFTC) issued an order filing and simultaneously settling charges against Australia and New Zealand Banking Group Ltd. (ANZ), an Australia-based firm that’s...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

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CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps - On August 19, The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments to existing rules relating...more

Katten Muchin Rosenman LLP

CFTC Further Extends Valuation Data Reporting Relief for SDs and MSPs

Katten Muchin Rosenman LLP on

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

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