News & Analysis as of

Swaps Market Participants

Stikeman Elliott LLP

CSA Publish Derivatives Data Reporting Transition Guidance

Stikeman Elliott LLP on

Amendments to swap data reporting rules are expected to be implemented by the Commodity Futures Trading Commission (CFTC) in December 2022. The Canadian Securities Administrators (CSA) have issued guidance to market...more

Cadwalader, Wickersham & Taft LLP

CFTC Sanctions Registered CTA for Operating Unregistered SEF

On September 26, the Commodity Futures Trading Commission (“CFTC”) published an order settling charges against Asset Risk Management, LLC (“ARM”), a registered commodity trading advisor (“CTA”) headquartered in Houston,...more

Goodwin

ISDA Publishes Dodd-Frank Security-Based Swap Protocol

Goodwin on

On March 15, 2021, ISDA published the ISDA 2021 Security-Based Swaps (SBS) Top-Up Protocol (the SBS Top-Up Protocol). The SBS Top-Up Protocol enables SBS dealers (SBSDs) and other market participants to comply with certain...more

Seyfarth Shaw LLP

Undeterred by the COVID-19 Pandemic, ARRC Publishes on April 8, 2020 a Methodology for Addressing Differences between LIBOR and...

Seyfarth Shaw LLP on

On April 8, 2020, the Alternative Reference Rate Committee (“ARRC”) agreed to align itself with the International Swaps and Derivatives Association, Inc. (“ISDA”), in recommending to the market a “spread adjustment”...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

WilmerHale

SEC Adopts Rule Amendments and Guidance Addressing Cross-Border Application of Certain Security-Based Swap Requirements

WilmerHale on

On December 18, 2019, the Securities and Exchange Commission (SEC) adopted a package of rule amendments, guidance and a related order to expand and improve the framework for regulating cross-border security-based 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

Vedder Price

SEC Issues New Rules for Security-Based Swaps

Vedder Price on

On December 18, 2019, the SEC adopted certain rule amendments to enhance the framework for regulating cross-border security-based swaps. Through this effort, the SEC established a broad security-based swap regulatory regime...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

WilmerHale

CFTC Ends 2019 with Rulemaking Flurry

WilmerHale on

The Commodity Futures Trading Commission (CFTC or Commission) at year-end issued one final and two proposed rulemakings. The proposed rules are potentially significant for all swap market participants, and the final rules are...more

Opportune LLP

LIBOR Phase-Out: Considerations for Oil & Gas Companies

Opportune LLP on

With over $370 trillion of global financial contracts referencing LIBOR (London Inter-bank Offered Rate), many oil and gas companies are curious about how the phase-out of LIBOR by 2021 could impact their organization. Many...more

Kramer Levin Naftalis & Frankel LLP

ISDA Implements Changes to the Credit Derivatives Definitions

In a continuing effort to address the advent of narrowly tailored credit events (NTCEs) in the CDS market, ISDA is now preparing for the implementation of the changes designed to deter market participants from running these...more

A&O Shearman

US and UK Regulators Issue Joint Statement on Credit Derivatives Markets

A&O Shearman on

The U.S. Commodity Futures Trading Commission, U.S. Securities and Exchange Commission and the U.K. Financial Conduct Authority have issued a joint statement regarding the use of "opportunistic strategies" in the credit...more

A&O Shearman

CFTC Considers Revamp of SEF Regulatory Framework

A&O Shearman on

Toward the end of 2018, the Commodity Futures Trading Commission (CFTC) proposed significant revisions to the framework governing swap trading through swap execution facilities (SEFs) and designated contract markets (DCMs)....more

Latham & Watkins LLP

CFTC Uncleared Swap Margin Rules to Take Effect in September

Latham & Watkins LLP on

While the US gears up for compliance with uncleared swap margin rules, cross-border application of the CFTC rules remains unclear. The US Commodity Futures Trading Commission (the CFTC) finalized its margin requirements...more

Proskauer Rose LLP

CFTC Brings Enforcement Action for Swap Reporting Violations

Proskauer Rose LLP on

The Commodity Futures Trading Commission (CFTC) recently brought its first enforcement action arising from the Dodd-Frank requirement that swap transactions be reported to a registered swap data repository (SDR). The CFTC has...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

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 49

In this issue: - Delaware Chancery Court Declines to Dismiss Fraud Claims Against Private Equity Fund and Directors - Agencies Amend Regulatory Capital and Liquidity Coverage Ratio Rules - FINRA Proposes...more

Katten Muchin Rosenman LLP

US Banking Regulators Propose Margin Requirements for Uncleared Swaps

On September 3, the Federal Reserve Board, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Federal Housing Finance Agency and Farm Credit Administration (collectively, Agencies) proposed...more

Morrison & Foerster LLP

The CFTC’S Cross-Border Application of the Dodd-Frank Act

After years of anticipation, the U.S. Commodity Futures Trading Commission in July 2013 issued more than 300 pages of “guidance” ostensibly to assist market participants in understanding the breadth of the extraterritorial...more

Latham & Watkins LLP

CFTC Staff to Host Position Limits and Aggregation Roundtable

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Market participants are encouraged to submit further comments to the Commission. The Commodity Futures Trading Commission (CFTC) on May 27, 2014 announced that it will hold a public roundtable at the CFTC on Thursday,...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - October 4, 2013

In this issue: - FINRA Proposes Rule to Require Alternative Trading Systems to Report Volume Information and Use Unique Market Participant Identifiers - SEC Issues Frequently Asked Questions Regarding Liability...more

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