News & Analysis as of

Swaps Trade Options

Cadwalader, Wickersham & Taft LLP

CFTC Extends OCR Final Rule Relief

On September 22, 2023, the Commodity Futures Trading Commission’s (the “CFTC” or the “Commission") Division of Market Oversight extended its no-action position regarding certain large trader reporting (“LTR”) obligations for...more

Opportune LLP

Increased Swaption Activity May Present Financial Reporting Challenges for Oil & Gas Companies

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Lower natural gas prices are causing E&P companies to get creative with their hedging strategies to lock in near-term cash flows above the dismal levels the market is currently offering. When hedging with options, it’s not...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

CBS isn’t the only large company with insider trading worries. In complaints made public yesterday, the SEC has accused Gene Levoff, Apple’s former senior director of corporate law and corporate secretary, of “repeatedly”...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Commission Sends MiFID II Draft RTS Back to ESMA for Revision - On March 17, Markus Ferber, MEP, the European Parliament's Rapporteur for MiFID II, published a press release announcing that the European Commission had...more

Orrick - Finance 20/20

CFTC Approves Final Rule to Amend the Trade Option Exemption by Eliminating Certain Reporting and Recordkeeping Requirements for...

Orrick - Finance 20/20 on

On March 16, the U.S. Commodity Futures Trading Commission approved a final rule that eliminated certain requirements “for trade option counterparties that are neither swap dealers nor major swap participants[.]”...more

Cadwalader, Wickersham & Taft LLP

CFTC Adopts Final Trade Option Rule

On March 16, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved amendments to the rules applicable to certain physically-settled options referred to as “trade options.” This final rule substantially...more

Latham & Watkins LLP

Dodd-Frank Almost 6 Years Later: Where Are We Now? Energy-Related Derivatives Regulation

Latham & Watkins LLP on

In the almost six years since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the US Commodity Futures Trading Commission (CFTC) has, in large part, finalized its rulemakings...more

Morrison & Foerster LLP

CFTC Proposes Relief from Trade Option Reporting and Recordkeeping Requirements for Commercial End Users

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

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Proposes to Reduce Trade Option Reporting Requirements for Commercial End-Users"

Trade options are physically settled over-the-counter options on most deliverable commodities (e.g., agricultural, energy, or metals) where the buyer is a producer, processor, commercial user or merchant of the commodity...more

Katten Muchin Rosenman LLP

CFTC Reissues FAQ on Commodity Options

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has reissued a document addressing frequently asked questions (FAQs) on commodity options. The FAQs document, which DMO originally issued on...more

Stinson - Corporate & Securities Law Blog

New Year Brings Changes To End User Reporting Requirements For Trade Options And Swaps

The first half of 2014 will bring changes to the end user reporting requirements for trade options and swaps—namely, (1) the commencement of the annual Form TO reporting requirement for unreported trade options and (2) a...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Re-Proposes Speculative Position Limit Rules For Futures, Options And Swaps On Physical Commodities

On November 5, 2013, the Commodity Futures Trading Commission (CFTC) voted 3-1 to re-propose rules to establish speculative position limits for futures, options and economically equivalent swaps on certain agricultural, metal...more

Katten Muchin Rosenman LLP

CFTC Staff Responds to FAQs Regarding Commodity Options

On September 30, CFTC staff issued responses to several frequently asked questions (FAQs) related to commodity options. Pursuant to Section 1a(47) of the Commodity Exchange Act, which defines the term “swap” to include an...more

Stinson - Corporate & Securities Law Blog

CFTC Responds To FAQ On Commodity Options

Today, the CFTC Division of Market Oversight published a response to frequently asked questions regarding commodity options, including reporting obligations with respect to trade options. The response clarified a few...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters

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

Stinson - Corporate & Securities Law Blog

CFTC No-Action Letter Allows Most End Users To Report All Trade Options On Annual Aggregate Basis

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

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