Podcast: CFTC Issues LIBOR Transition Relief for Swaps
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
An initial question faced by a new hedge fund manager is whether or not registration with the U.S. Commodity Futures Trading Commission (CFTC) will be required. Limited Trading Exemption - CFTC Rule 4.13(a)(3), which...more
The Office of Information and Regulatory Affairs recently released the semi-annual, Fall 2023 regulatory agenda (“Agenda”). The Agenda outlines the SEC Chairman’s rulemaking priorities over the next 12 months. The Agenda...more
This advisory is the latest Commodity Futures Trading Commission ("Commission" or "CFTC") staff action conveying a Commission or staff view that CFTC registrants conducting business in nontraditional ways may need to register...more
On September 27, 2022, 15 broker-dealers and one investment adviser agreed to pay more than $1.8 billion in total civil penalties to the US Securities and Exchange Commission (SEC), and, for those same companies or affiliates...more
Eight years after the Commodity Futures Trading Commission (CFTC or Commission) established a comprehensive swap data reporting and public dissemination regulatory regime, on September 17, the Commission adopted extensive...more
Investment Advisers - ANNUAL COMPLIANCE REVIEWS - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and procedures...more
The U.S. Securities and Exchange Commission on November 25, 2019 unanimously approved for publication a rule proposal related to the use of derivatives and certain other transactions by companies that have elected to be...more
SEC/CORPORATE - SEC Adopts Additional Rules for Security-Based Swaps - On June 21, the Securities and Exchange Commission adopted a panoply of final rules dealing with the following aspects of the regulation of...more
Four related Securities and Exchange Commission-registered investment advisers and/or broker-dealers agreed to pay a collective penalty close to US $100 million to resolve charges related to their purported implementation and...more
SEC Approves Rules to Ease Investor Access to Exhibits in Company Filings - On March 1, 2017, the Securities and Exchange Commission (SEC) voted to adopt rule and form amendments that will require issuers to include a...more
The Commission prevailed at trial in a market manipulation case. The trial followed a series of settlements and a grant of summary judgment in the Commission’s favor as to one defendant. The remaining defendant, a former NFL...more
"Wherefore Art Thou Due Process?" Part III - Why it matters: It is time for another installment in our continuing "Wherefore Art Thou Due Process?" coverage into the ongoing constitutional challenges to the SEC's...more
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
CME Group Files Disciplinary Actions for Trading Ahead of Block Trades and Failure to Supervise an Employee Engaging in Disruptive Trading Activities - In two cases of first impression, CME Group exchanges brought and...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
Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more
The Commission announced its largest whistleblower action this week – an award to a person overseas of over $30 million. The agency also filed a series of actions this week....more
In this issue: - Delaware Court of Chancery Rules That a Major Debt Holder and 48 Percent Stockholder Is a Controlling Stockholder and Owes Fiduciary Duties to Minority Stockholders - Delaware Court of Chancery...more
In this issue: - SEC Division of Corporation Finance Issues Guidance on Rule 506(c) Private Placements - SEC Issues No-action Relief Regarding Registration of M&A Brokers - CFTC Issues Guidance on New...more
The SEC has stayed the implementation date of its final rules establishing a permanent registration and record-keeping regime for municipal advisors until July 1, 2014. The new rules are required by the Dodd-Frank Wall Street...more
The U.S. Commodity Futures Trading Commission (“CFTC”) has issued final rules (“Final Rules”) setting minimum block trade sizes for different types of CFTC regulated swaps that are permitted to be executed off-facility and...more
The Commodity Futures Trading Commission’s Division of Market Oversight has issued no-action relief from the prohibition in CFTC Regulation 43.6(h)(6) on the aggregation of orders for different accounts to satisfy minimum...more
Investment advisers with clients (including funds or separate accounts) that use swaps are reminded to have such clients sign up to the ISDA March 2013 DF Protocol (the “March DF Protocol”) by July 1, 2013....more
On 8 March 2013, The International Swaps and Derivatives Association, Inc (“ISDA”) published the ISDA 2013 EMIR NFC Representation Protocol (the “Protocol”). Adherence to the Protocol provides parties to ISDA Master...more
In this issue: - NASDAQ Proposes Internal Audit Function Requirement for Listed Issuers - FINRA’s Frequently Asked Questions on Electronic Blue Sheet Submissions Updated Regarding Order Execution Time -...more