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Swaps Swap Market

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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Finalizes Cross-Border Swaps Rule

On July 23, 2020, the Commodity Futures Trading Commission (CFTC or Commission) voted 3-2 to approve a final rule (Final Rule) on the cross-border application of certain swap provisions under the Commodity Exchange Act (CEA)....more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

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

Troutman Pepper

Update: Prudential Regulators Delay Compliance Deadline for New Swap Margin Rules

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If you have been following our alerts on the pending deadlines (and the delays of these deadlines by certain regulators) of the new swap variation margin rules (New Swap Margin Rules) that were due to go into effect on March...more

Troutman Pepper

Update: CFTC Delays Compliance Deadline for New Swap Margin Rules

Troutman Pepper on

Although the letter technically does not delay the effective date of March 1, 2017, from the perspective of the buy side, the letter functions as a “grace period,” and the compliance date has been moved to September 1, 2017....more

Troutman Pepper

Documentation for the New Swap Margin Rules and Thoughts for the Buy Side and End Users

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Because of the implementation of new regulatory requirements relating to both variation and initial margin for swaps, swap documentation for many market participants is about to become much more complicated....more

Holland & Knight LLP

Insurance Companies Need to Prepare for Swap Margin Rules in Effect on March 1, 2017

Holland & Knight LLP on

March 1, 2017, is the scheduled implementation date applicable for all insurance companies for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules. Although the...more

Stinson - Corporate & Securities Law Blog

CFTC Extends Swap Dealer De Minimis Phase-In Period

As has been rumored in recent weeks, the CFTC has adopted an order establishing December 31, 2018 as the swap dealer registration de minimis threshold phase-in termination date. With this approval, the de minimis threshold...more

Stinson - Corporate & Securities Law Blog

CFTC Chief Supports Extension of Swap Dealer De Minimis Exemption

Under current CFTC rules, market participants who exceed $8 billion in gross notional swap dealing activity over a twelve-month period are required to register with the CFTC as swap dealers during the phase-in period...more

Cadwalader, Wickersham & Taft LLP

Prudential Regulators Release Final Margin Rules for Swaps

On October 22, 2015, the Federal Deposit Insurance Corporation held an open meeting at which it voted to adopt: (i) final rules governing margin and capital requirements for uncleared swaps and (ii) an interim final rule to...more

Orrick - Finance 20/20

CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps

Orrick - Finance 20/20 on

On August 19, The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments to existing rules relating to swap data reporting in connection with cleared swaps. The amendments are aimed at providing additional...more

Dorsey & Whitney LLP

The SEC Commissioners Speak: Part I

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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

Morrison & Foerster LLP

Margin for Uncleared Swaps: A Critical Look at the CFTC and Prudential Regulators Proposals

Last fall both the Commodity Futures Trading Commission (“CFTC”) and five U.S. prudential banking regulators (the “Prudential Regulators”) released proposed rules for margin requirements for uncleared swap transactions for...more

Perkins Coie

Financial Services Bulletin: Action at Federal Agencies

Perkins Coie on

The Federal Reserve Board Proposes Repeal of Unfair or Deceptive Acts Rules - On Friday, August 22, 2014, the Federal Reserve Board (the "Board") requested comments on its proposal to repeal its Regulation AA, which...more

Dorsey & Whitney LLP

This Week In Securities Litigation

Dorsey & Whitney LLP on

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

Eversheds Sutherland (US) LLP

Regulators Publish Re-proposed Margin Requirements for Uncleared Swaps

On September 3, 2014, the Board of Governors of the Federal Reserve System (the Board) jointly adopted, with certain federal banking regulators, re-proposed rules that will require registered swap dealers, security-based swap...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

Katten Muchin Rosenman LLP

CFTC Extends No-Action Relief for Certain Transaction-Level Requirements for Non-US Swap Dealers

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

European Banking Authority Publishes Opinion on European Commission's Proposed Amendments to ITS - On April 16, the European Banking Authority (EBA) published via its website an opinion dated April 4, 2014 on...more

Katten Muchin Rosenman LLP

CFTC Delays Transaction-Level Requirements for Certain Non-US SD Transactions

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has delayed until January 14, 2014 the effectiveness its Advisory 13-69 issued on November 14 in which it took the position...more

Proskauer Rose LLP

Upcoming Deadlines for Private Funds that Trade Swaps

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Some of the key changes to the swaps markets contemplated by the Dodd-Frank Act are starting to take effect. Some key upcoming deadlines affecting private investment funds are highlighted below. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impending Swap Reporting Requirements to Impact All Swap Market Participants

All swap market participants, including commercial end-users, should be aware of the upcoming April 10 deadline for Commodity Futures Trading Commission (CFTC) swap reporting and recordkeeping requirements under Parts 43, 45...more

Eversheds Sutherland (US) LLP

CFTC Issues First Set of Mandatory Clearing Determinations and Time-Limited No-Action Relief

On November 28, the Commodity Futures Trading Commission (CFTC) issued final clearing determinations (Final Determinations) with respect to four classes of interest rate swaps (IRS) and two classes of credit default swaps...more

Perkins Coie

Financial Services Bulletin: Action at the SEC, DC Circuit Court, and the CFTC

Perkins Coie on

In This Issue: - SEC Proposes Security-Based Swap Rules - Court Challenge Filed to the SEC's "Conflict Mineral" Rules - CFTC Proposes Security-Based Swap Rules...more

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