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
The Financial Industry Regulatory Authority (“FINRA”) recently kicked off a “sweep” examination with its August 2021 Targeted Exam Letter on “practices and controls related to the opening of options accounts and related...more
The U.S. equity, options and futures markets have adopted market-wide circuit breakers that automatically halt trading across markets in the event of severe market declines, as measured by certain benchmarks against the S&P...more
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
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
Here’s all you need to know from the Fed minutes released yesterday, including next month’s rate increase, an apparent plan to continue rate hikes at their gradual pace (unless White House trade policies “scramble their...more
What has happened? A US federal court has ordered Dillon Michael Dean and his UK-registered company, The Entrepreneurs Headquarters Ltd (TEH), to pay over $1.9 million in "civil monetary penalties and restitution"....more
Legislative changes - The Constitution of Business - On 30 April 2018, the so-called Constitution of Business enters into force (with the reservation of a small number of provisions entering into force at later dates)....more
The Fed’s Open Markets Committee meets today, and despite relatively robust economic numbers of late, the lack of oped-for inflation (among other things) is likely to keep the Fed from moving on interest rates again at this...more
Before booking your airfare, be mindful of these potential issues. In light of liberalized trade with Iran made possible by the Office of Foreign Assets Control’s (OFAC’s) General License H and the relaxation of US...more
On March 16, 2016, the U.S. Commodity Futures Trading Commission (CFTC) took action to further reduce the regulatory requirements associated with commodity trade options through issuance of a final rule that took effect on...more
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
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
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
The CFTC approved a final rule today that removes trade option* reporting and recordkeeping requirements applicable to non-swap dealer/major swap participant counterparties (“Non-SD/MSPs” or “end users” for purposes of this...more
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
The CFTC provides the market additional time to submit Form TO while considering further amendments to trade option reporting rules. On February 18, 2016, the US Commodity Futures Trading Commission's (the CFTC) Division...more
The Commodity Futures Trading Commission’s Energy and Environmental Markets Advisory Committee will hold a public meeting on July 29. The Advisory Committee will discuss how energy and environmental markets would be affected...more
On July 8, the Internal Revenue Service (IRS) issued two notices (Notice 2015-47, 2015-30 IRB 1, and Notice 2015-48, 2015-30 IRB 1) targeting the use of Basket Option Contracts and Basket Contracts as tax avoidance...more
Relying on a data-driven statistical analysis conducted by the Division of Economic and Risk Analysis (DERA), the SEC recently commenced administrative proceedings against an investment advisor, Welhouse & Associates, Inc.,...more
NYDFS Finalizes BitLicense Regulations - On June 3, 2015, the New York Department of Financial Services released its final BitLicense regulations, which it described as "the first comprehensive framework for regulating...more
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
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
Former Goldman Sachs, Morgan Stanley, BNP Paribas and Societe Generale bankers have announced a new futures and options derivatives-trading platform for bitcoin. The derivatives, tied to the price of bitcoin, will enable...more
FINRA Rule 2360 requires that members file reports for each account that has an aggregate position of 200 or more options contracts on the same side of the market covering the same underlying security or index. The reports...more