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
On June 4, the CFTC issued a no-action letter providing relief from the clearing requirement for swaps entered into by eligible treasury affiliates....more
The Commodity Futures Trading Commission recently released two no-action letters (i) extending relief provided to futures commission merchants (FCMs) relating to risk-based limits for bunched orders and (ii) providing relief...more
On April 1, 2013, the Commodity Futures Trading Commission (“CFTC”) approved a final rule (Regulation 50.52) exempting swaps between certain affiliated entities from the clearing requirements of the Commodity Exchange Act...more
In this issue: - SEC Issues Proposal Regarding Cross-Border Security-Based Swap Activities - CFTC Staff Issues No-Action Letters - Delaware Court Dismisses Securities Fraud Action Against Power Plant...more
Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more
In this issue: - SEC and CFTC Adopt Joint Rules to Help Protect Investors from Identity Theft - CME Block Trade Advisories Clarify Nonpublic Information Restrictions - CFTC Staff Issues No-Action...more
On April 9, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight, responding to requests from multiple interested parties, issued a no-action letter (the No-Action Letter) extending the April...more
The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more
The CFTC has issued a no-action letter that effectively extends the dates for swap counterparties who are not swap dealers (SDs) or major swap participants (MSPs) to come into compliance with the agency’s reporting rules...more
On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk provided no-action relief (the No-Action Letter) from certain reporting requirements relating...more
The CFTC Division of Market Oversight (DMO) has issued a no-action letter that will allow most swaps end users to report all trade options on an annual aggregate basis. Trade options are commodity options (which include some...more
In this issue: - SEC Advisory Committee on Small and Emerging Companies Makes Recommendations - SEC Provides Guidance Regarding Social Media and Regulation Fair Disclosure (Regulation FD) - SEC Amends...more
The CFTC’s Division of Clearing and Risk issued a no-action letter that provides relief from required clearing for a limited set of “stub swaps.” These are swaps that remain after the partial novation or partial termination...more
In This Issue: *Financial Industry Developments - OCC Guidance on Transition Periods under Section 716 of the Dodd-Frank Act - CFTC Reporting of Swap Transactions and Swap Dealer Registration - Department...more
From December 14 through December 31, 2012, the CFTC released the following no-action letters: - December 14: Timeline for Swap Dealer Compliance with Large Swap Trader Reporting Rules...more
Staff of the Commodity Futures Trading Commission released a series of letters relating to a variety of regulatory changes, including the extraterritorial application of certain CFTC requirements, registration relief, swap...more
In this issue: - CII Submits Rule 10b5-1 Rulemaking Petition to the SEC - ISS Publishes Updated FAQs for its Proxy Voting Policies - CFTC Issues Final Order on Cross-Border Swaps - CFTC Issues No-Action...more
Commodity Futures Trading Commission Staff have released several no-action letters relating to various requirements associated with swap trading, including swap dealer (SD) reporting requirements, SD chief compliance officer...more
The Commodity Futures Trading Commission (CFTC) released a series of staff letters relating to various issues arising under rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, including chief...more
On December 10, the CFTC issued a letter providing reporting parties under Parts 20, 45 and 46 of the CFTC’s regulations with time-limited no-action relief from requirements to report certain identifying information regarding...more
On December 13, the CFTC issued a letter providing relief from the post-allocation swap timing requirement of § 45.3(e)(ii)(A). The no-action letter permits parties to a swap to fulfill reporting obligations for...more
The staff of the U.S. Securities and Exchange Commission (the “SEC”) released no action relief (the “Letter”) addressed to recipients of 18 prior orders (the “Prior Orders”) granting exemptive relief to launch...more
On December 6, the CFTC issued a no-action letter that provides swap dealers and major swap participants with relief from the requirement to disclose the pre-trade mid-market mark to counterparties in certain foreign exchange...more
On November 28, the CFTC Division of Clearing and Risk issued time-limited no-action letters granting relief from required clearing under Section 2(h)(1)(A) of the Commodity Exchange Act and the newly adopted Part 50...more
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