Slick Transition: ICE Clear Europe’s Paul Swann Talks NYSE Integration
Open for Business: SEF Competition Heating Up in the New Market Structure
Open for Business: SEFs Navigate the New Regulatory Environment
CFTC’s Scott O’Malia Calls for a Plan of Action on Swap Data
Cross-Border Regulation of Swaps Update from ISDA's Robert Pickel (Part 1)
An Update on SEF, IDB and Swap Regulation from Chris Ferreri of ICAP
Jill Sommers Reflects on the CFTC, Dodd-Frank, and Her Future
CFTC Proposal Poses “Monumental” Challenge to FCMs
The CFTC has proposed rules that would define the reach of Dodd-Frank Act margin requirements in cross-border swap transactions.
On June 29, 2015, the US Commodity Futures Trading Commission (CFTC) proposed regulations...more
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
The broad definition of a “swap” in the Dodd-Frank Act, read literally, would encompass many transactions that Congress never intended to cover, so the SEC and the CFTC have jointly promulgated regulations that provide that...more
Et tu, CFE? CBOE Futures Proposes Amended Disruptive Practices Rules and New Related Policies and Procedures:
CBOE Futures Exchange became the latest designated contract market to propose specific rules to ban disruptive...more
The CFTC has combined an entity-level approach with a transaction-level approach in its proposed cross-border uncleared swap margin requirements.
On October 3, 2014, the Commodity Futures Trading...more
Regulatory Developments -
Client Alert: SEC Proposes Pay for Performance Rules:
Goodwin Procter’s Capital Markets practice has issued a Client Alert on the SEC’s proposed rule that would require most public...more
With recent release, the CFTC hopes to eliminate market uncertainty on forward contracts with embedded volumetric optionality.
UPDATE (June 18, 2015): On May 12, 2015, the CFTC adopted the Proposal as proposed (as used...more
The SEC issued an Investor Alert which says fantasy stock trading for small amounts of money can violate provisions of securities laws implemented by the Dodd-Frank Act. I bet the Congressional drafters of these provisions...more
In This Issue:
- Meeting of the SEC Advisory Committee on Small and Emerging Companies
- FINRA Requests Comment on a Proposed Rule to Require Delivery of an Educational Communication to Customers of a Transferring...more
If finalized, the proposed rule would be the SEC’s second major step toward finalizing the cross-border rules for security-based swaps under the Dodd-Frank Act.
On April 29, 2015, the US Securities and Exchange...more
On May 18, 2015, the Commodity Futures Trading Commission (“CFTC”) published a final interpretation on forward contracts with embedded volumetric optionality (“Final EVO Interpretation”).1 In the Final EVO...more
On May 8, 2015, the Treasury Department and the Internal Revenue Service published temporary and proposed regulations under IRC §§ 446 and 956 (T.D. 9719; REG-102656-15), clarifying when nonperiodic payments made pursuant to...more
EBA Final Report on Guidelines on Triggers for Use of Early Intervention Measures Under BRRD -
On May 8, the European Banking Authority (EBA) published its final report (EBA/GL/2015/03) on guidelines on triggers for the...more
Discussion and Analysis -
Securities and investment advisory services offered through . . .
That phrase is ubiquitous among small and “independent” financial services firms, regularly appearing in 6-point or...more
On April 30, 2015, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to the trade option exemption (the “Proposal”) that would reduce reporting and...more
On April 29, 2015, the US Securities and Exchange Commission (SEC) proposed new rules to enhance its oversight of non-US firms’ security-based swap activity in the United States. The proposal, if adopted, will have important...more
OSC Investor Advisory Panel annual report.
The Ontario Securities Commission (OSC) Investor Advisory Panel submitted its 2013-14 annual report. The report summarizes the Panel’s current activities and priorities as well...more
On March 10, the Commodity Futures Trading Commission released an initial response to the order of the US District Court for the District of Columbia in SIFMA v. CFTC remanding eight swaps-related rulemakings to the CFTC. As...more
The SEC Speaks conference has traditionally been a forum in which the agency reviewed significant recent undertakings and indicated its future direction. This year was no different. Four of the five Commissioners addressed...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act’s mandatory clearing requirement for interest rate swaps and certain credit default swaps has been in place for quite some time. However, the clearing requirement...more
The SEC Proposes JOBS Act Registration Rules -
On Thursday, December 18, 2014, the Securities and Exchange Commission (the “SEC”) proposed rule amendments to implement Title V and Title VI of the Jumpstart Our Business...more
Editor’s Note -
CFTC Commissioner Giancarlo Proposes “Pro-Reform Reconsideration” of the Swaps Trading Rules. On January 29, CFTC Commissioner J. Christopher Giancarlo published a whitepaper titled “Pro-Reform...more
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
The House and Senate have passed legislation which provides that swap end-users do not have to provide initial and variation margin for uncleared swaps as previously required by the Dodd-Frank Act.
The provision is...more
The so-called “Push-Out Rule” relating to swap activity conducted by banks has been significantly narrowed in scope by a provision in the Consolidated and Further Continuing Appropriations Act, 2015 (Spending Bill), which was...more
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