News & Analysis as of

Swaps Commodities Futures Trading Commission No-Action Relief

Cadwalader, Wickersham & Taft LLP

CFTC Extends OCR Final Rule Relief

On September 22, 2023, the Commodity Futures Trading Commission’s (the “CFTC” or the “Commission") Division of Market Oversight extended its no-action position regarding certain large trader reporting (“LTR”) obligations for...more

Morgan Lewis

CFTC No-Action Relief for Registrant and Market Participant COVID-19 Response

Morgan Lewis on

Many Commodity Futures Trading Commission registrants and other market participants are responding to the coronavirus (COVID-19) pandemic by implementing business continuity plans that move personnel from their “normal...more

Skadden, Arps, Slate, Meagher & Flom LLP

COVID-19: CFTC Issues No-Action Relief for Market Participants

On March 17, 2020, in response to the COVID-19 (coronavirus) pandemic, the Commodity Futures Trading Commission (CFTC) Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) issued...more

A&O Shearman

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

A&O Shearman on

The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more

Latham & Watkins LLP

CFTC Issues No-Action Relief for Derivatives Market IBOR Transition

Latham & Watkins LLP on

While not unlimited, the relief is welcome for counterparties seeking to transition to risk-free rates for legacy swaps. The US Commodity Futures Trading Commission (CFTC) has issued no-action relief to help market...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Illusory Promise or Real Change? Transition at CFTC Brings Hope for Dodd-Frank Act Revisions

Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more

K&L Gates LLP

CFTC Issues No-Action Relief for Floor Traders to Exclude SEF-Executed Cleared Swaps from the Swap Dealer De Minimis Calculation

K&L Gates LLP on

Introduction - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for floor traders to “encourage new liquidity providers to trade cleared swaps on registered venues without...more

A&O Shearman

US Commodity Futures Trading Commission Provides Margin Relief for Legacy Swaps

A&O Shearman on

In response to a request from the International Swaps and Derivatives Association, the Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight issued no-action relief that will permit swap...more

Orrick - Finance 20/20

DSIO Issues Time-Limited, Conditional No-Action Relief for Excluding Certain Loan-Related Swaps from Counting toward the Swap...

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (“DSIO“) announced “conditional, time-limited no-action relief to a banking entity for not counting...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

Orrick - Finance 20/20

CFTC Division of Market Oversight Issues No-Action Relief from Certain Timing Requirements Regarding SEF Chief Compliance Officer...

Orrick - Finance 20/20 on

On November 20, 2017, the Commodity Futures Trading Commission (“CFTC“) provided “no-action relief to swap execution facilities [] from the timing requirement within CFTC regulation 37.1501(f)(2), which requires a chief...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements - On November 14, 2017, the U.S. Commodity Futures Trading Commission's Division ("CFTC") of Market...more

Orrick - Finance 20/20

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements

Orrick - Finance 20/20 on

On November 14, 2017, the U.S. Commodity Futures Trading Commission’s Division (“CFTC“) of Market Oversight extended time-limited no-action relief to swap execution facilities (“SEFs“) from certain requirements under the...more

Eversheds Sutherland (US) LLP

CFTC No-Action Relief from SEF Trading for Package Transactions

Earlier this week, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight extended existing no-action relief from trading on a swap execution facility for package transactions until November 15, 2020. ...more

Orrick - Finance 20/20

CFTC Staff Extends Time-Limited No-Action Relief on the Applicability of Transaction-Level Requirements in Certain Cross-Border...

On July 25, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) “issued a time-limited no-action letter that extends relief to swap dealers [] registered with the CFTC that are established under the laws of...more

Orrick, Herrington & Sutcliffe LLP

Derivatives In Review - May 2017

CME and LCH Amend Rulebooks on Variation Margin - Market participants historically have characterized cleared derivatives as being "collateralized-to-market", treating variation margin transfers as daily collateral...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Regulators Provide Some Flexibility on the Swaps Variation Margin Compliance Deadline"

On February 23, 2017, U.S. federal banking regulators (Prudential Regulators), European regulators and the International Organization of Securities Commissions (IOSCO) issued statements clarifying their expectations on...more

Orrick - Finance 20/20

CFTC Extends No-Action Relief for Swap Execution Facilities from Certain “Block Trade” Requirements

Orrick - Finance 20/20 on

On October 7, 2016, the U.S. Commodity Futures Trading Commission (“CFTC“) Division of Market Oversight extended time-limited no-action relief for swap execution facilities from the “occurs away” requirement from the...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

FHFA Releases 2015 Report to Congress - On June 15, 2016, the Federal Housing Finance Agency's "Report to Congress" for 2015 was released. The document, required under federal law, analyzes Fannie Mae, Freddie Mac and...more

Orrick - Finance 20/20

CFTC Extends No-Action Relief to SEFs and DCMs from Certain CFTC Regulations for Correction of Errors

Orrick - Finance 20/20 on

The U.S. Commodity Futures Trading Commission (CFTC) extended the relief contained in CFTC Letter No. 15-24 that allowed swap execution facilities and designated contract markets to correct certain errors that would lead to a...more

Morgan Lewis

CFTC Staff Clarifies Registration Relief Available to Non-US Asset Managers

Morgan Lewis on

No-action relief confirms that non-US asset managers may rely on an exemption from CFTC registration when trading uncleared swaps in the United States for the accounts of their non-US clients, an issue that had been in doubt...more

Dechert LLP

CFTC Staff Issues No-Action Relief Helpful for Non-U.S. Commodity Pool Operators and Commodity Trading Advisors

Dechert LLP on

The U.S. Commodity Futures Trading Commission (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) provided no-action relief on February 12, 2016 to commodity pool operators (CPOs) and commodity trading advisors...more

Katten Muchin Rosenman LLP

Extension of Time-Limited, Conditional No-Action Relief Regarding Masking Certain Reportable Identifying Information

On January 15, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) issued CFTC letter 16-03 (“Letter”) providing a conditional, time-limited extension of the relief provided in CFTC Letter 13-41,...more

Morrison & Foerster LLP

CFTC Staff Issues No-Action Relief from Mandatory Swaps Clearing for Small Bank Holding Companies, Small Savings and Loan Holding...

On January 8, 2016, the Division of Clearing and Risk (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters providing relief from the mandatory clearing requirement for swaps under Section...more

Katten Muchin Rosenman LLP

CFTC Further Extends No-Action Relief for Certain Package Transaction Swaps

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has issued CFTC Letter No. 15-55, extending until November 15, 2016, time-limited no-action relief for certain swaps executed as part of a package...more

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