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CFTC Approves Final Rule on Post-Trade Name Give-Up on Swap Execution Facilities

The CFTC has adopted a final rule to prohibit the controversial practice of post-trade name give-up for swaps that are executed anonymously through a Swap Execution Facility (SEF) and are intended to be cleared. Although the...more

CFTC Considers New Approach to Regulation of Electronic Trading

In the wake of considerable market criticism of prior proposals, the CFTC has proposed a new approach to addressing certain risks of electronic trading. The CFTC has now officially withdrawn, on a 3-2 vote, its controversial...more

CFTC Approves Proposed and Final Rules on Clearing, Margin and Consumer Privacy

The CFTC has recently published the following final and proposed rules codifying previously issued no action relief and restoring consumer information privacy policies and procedures...more

7/2/2020  /  CFTC , Enforcement Actions

CFTC Issues Final Interpretive Guidance on ‘Actual Delivery’ of Digital Assets

The Commodity Futures Trading Commission (the CFTC) has issued long-awaited final interpretive guidance regarding the “actual delivery” exception to retail commodity transactions involving digital or virtual currencies under...more

CFTC Approves Proposed Rule on Post-Trade Name Give-Up on Swap Execution Facilities

In the wake of significant market discussion, the CFTC has proposed an amendment to Part 37 of the Commission’s regulations to eliminate the practice of “post-trade name give-up” for swaps traded on certain swap execution...more

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more

SEC Finalizes Capital, Margin and Segregation Requirements

As a further step towards the implementation of its security-based swap regime, the Securities and Exchange Commission (SEC) has adopted a number of long-awaited capital, margin and segregation requirements for security-based...more

SEC Proposes Modifications to Cross-Border Application of Security-Based Swaps Regime

The Securities and Exchange Commission (SEC) continues to take steps toward implementation of its security-based swap (SBS) dealer registration framework. A particular area of concern for market participants has been how the...more

CFTC Proposes Amendments to DCO Core Principle Regulations

The Commodity Futures Trading Commission (CFTC) has proposed a series of changes to its general regulations governing derivatives clearing organizations (DCOs). The CFTC has stated that the proposed amendments are intended to...more

CFTC Proposes Updated Swap Data Reporting Regulations

The Commodity Futures Trading Commission (CFTC) has proposed the first installment of a series of amendments to its rules relating to swap data repositories (SDRs) and reporting of swap data. The proposed amendments, which...more

ISDA Proposes Amendments to the 2014 ISDA Credit Derivatives Definitions Relating to Narrowly Tailored Credit Events

On March 6, 2019, the International Swaps and Derivatives Association (ISDA) published proposed amendments to the 2014 ISDA Credit Derivatives Definitions relating to so-called narrowly tailored credit events (NTCEs). ISDA...more

CFTC Divisions Outline Examination Priorities for 2019

On February 12, 2019, the Commodity Futures Trading Commission (CFTC) published the 2019 examination priorities for its Division of Market Oversight (DMO), Division of Swap Dealer & Intermediary Oversight (DSIO) and Division...more

CFTC Considers Revamp of SEF Regulatory Framework

Toward the end of 2018, the Commodity Futures Trading Commission (CFTC) proposed significant revisions to the framework governing swap trading through swap execution facilities (SEFs) and designated contract markets (DCMs)....more

CFTC Chair Outlines Further Steps to Swaps Trading Rules Reform

On April 26, 2018, Commodity Futures Trading Commission (CFTC) Chairman J. Christopher Giancarlo and Chief Economist Bruce Tuckman published a white paper on potential reforms to the CFTC’s swaps trading rules....more

CFTC Adopts Final Rules Regarding the Cross-Border Application of Its Swap Margin Requirements

On May 24, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) adopted a final rule defining the cross border application of its margin requirements for uncleared swaps. The final rule covers all swap dealers and...more

EU Clearing Obligation for Interest Rate Swaps Looms

Implementation of the obligation for central clearing of OTC derivatives under the European Market Infrastructure Regulation now seems imminent. The European Commission has adopted a Delegated Regulation that would impose a...more

CFTC Proposes New Approach to the Cross-Border Application of Margin Requirements

The US Commodity Futures Trading Commission (“CFTC”) has taken another step in refining its framework for cross-border activities, with a new set of proposed rules applicable to the cross-border application of margin...more

Initial Swap Trading Requirements Come into Effect—Limited Relief for Packaged Trades and Some EU Facilities

The Commodity Futures Trading Commission has imposed for the first time a requirement that certain swaps be traded on a regulated market. Beginning February 15, 2014, certain cleared interest rate swaps and index credit...more

Ready for the Volcker Rule? What to Look For

Over two years after publication of a proposed regulation, a final regulation implementing the so-called “Volcker Rule” is expected to be adopted tomorrow by the five US Federal financial regulatory agencies. Two of them —...more

CFTC Grants No-Action Relief From Clearing Requirement for Certain Treasury Affiliates

On June 4, 2013, the Division of Clearing and Risk (the “Division”) of the US Commodity Futures Trading Commission (the “CFTC”) granted limited no-action relief from the mandatory clearing requirement for swaps entered into...more

CFTC Swap Reporting No-Action Relief Granted; Other Dodd-Frank Deadlines Approaching

On April 9, 2013, the US Commodity Futures Trading Commission (the “CFTC”) granted last minute no-action relief from portions of the CFTC’s swap reporting rules. The relief delays certain compliance deadlines for many swap...more

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