The Global Markets Advisory Committee (“GMAC”) of the U.S. Commodity Futures Trading Commission (“CFTC”) issued on June 4, 2024, a report on cleared derivatives and recommendations for non-cleared derivatives that will be of...more
This post is the next installment in a multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”)....more
This post continues our multi-part series on proposed CFTC Regulation §1.44 (the “Proposed Rule”).
If adopted, the Proposed Rule will require every futures commission merchant (“FCM”) to ensure that a customer does not...more
January 29, 2024, marks the end of an era for the interest rate derivatives (“IRD”) markets, since on this date the International Swaps and Derivatives Association (“ISDA”) and Clarus Financial Technology (“CFT”) published...more
Background -
The governing agreements for a wide range of transactions, from the most basic financing arrangements to the most complex derivatives trading relationships, frequently include a “cross-default” event of...more
Managing a company’s cash and financial assets equates to managing a company’s risks. This is axiomatic. Derivatives—and related contractual arrangements—have been widely used for risk management purposes in the financial...more