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CFTC 2020 Enforcement and Regulatory Developments and a Look Forward

2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more

Preparing for Security-based Swap Dealer Registration: Comparing SEC & CFTC Regulatory Requirements

The Securities and Exchange Commission (SEC) security-based swap dealer (SBSD) rules have finally been issued, and a large amount of work will be required to comply. The good news is there is a foundation to build on, given...more

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

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

The SEC Adopts Security-Based Swap Rules Governing Risk Mitigation Techniques for Uncleared Security-Based Swaps

On December 18, 2019, the Securities and Exchange Commission (the SEC or Commission) adopted new rules pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) requiring the...more

The SEC's Security-Based Swap Recordkeeping and Reporting Rules

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

The SEC Adopts Security-Based Swap Rules Governing Capital, Margin and Segregation

On June 21, 2019, the Securities and Exchange Commission (SEC or Commission) adopted a package of rules and rule amendments (Rules) that set forth the capital, margin and segregation requirements for security-based swap...more

New Joint Audit Committee Regulatory Alerts

On May 14, 2019, the Joint Audit Committee (JAC) issued two regulatory alerts calling for futures commission merchants (FCMs) to review policies and procedures and account agreements in situations where an FCM carries...more

CFTC Announces Whistleblower Award Totaling More Than $2 Million To Company Outsider

On March 4, 2019, the US Commodity Futures Trading Commission (CFTC) announced a whistleblower award totaling more than $2 million to a company outsider who contributed information through independent analysis that led to a...more

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