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Unpacking CFTC Letters 25-09 and 25-10

Derivatives market participants continue to process the implications of two significant interpretive letters issued by the Commodity Futures Trading Commission (CFTC) staff earlier this year. Letter 25-09 effectively...more

A More Business-Friendly Approach to Innovation, Risk Management and Derivatives Regulation: What to Expect From Incoming CFTC...

President Donald Trump's nomination of Brian D. Quintenz to serve as Chairman of the Commodity Futures Trading Commission (CFTC or Commission) portends a potential shift towards a more business-friendly regulatory approach to...more

Foreign Listed Stock Index Futures and Options Approvals January 2025

Attached please find the updated Foreign Listed Stock Index Futures and Options Approvals Chart, current as of January 21, 2025. All prior versions are superseded and should be discarded. Please note the following...more

New Administration, New Direction? What Swap Dealers Can Expect From CFTC Post-2024 Election

The 2024 US presidential elections may signal a shift in the Commodity Futures Trading Commission’s (CFTC or Commission) regulatory and enforcement approach. Under the incoming Trump administration, the CFTC could steer...more

CFTC Issues Final Guidance for Listing Voluntary Carbon Credit Derivatives

After five years of consultations, public meetings and roundtable discussions, the Commodity Futures Trading Commission (CFTC or Commission) has issued final regulatory guidance (Final Guidance) for exchanges, which list...more

CFTC Settles Enforcement Action Against Commodity Trading Firm for Alleged Fraud in Connection with Physical Commodity Trading...

Emphasizing its broad authority over fraud solely in connection with commodities – not just fraud in connection with derivatives referencing commodities – the Commodity Futures Trading Commission settled an enforcement action...more

Foreign Listed Stock Index Futures and Options Approvals December 2023

Attached please find the updated Foreign Listed Stock Index Futures and Options Approvals Chart, current as of December 19, 2023. All prior versions are superseded and should be discarded. Please note the following...more

CFTC Proposes Voluntary Carbon Credit Derivatives Market Guidance

After two years of examining carbon markets, the Commodity Futures Trading Commission (CFTC) proposed measures focused on improving integrity, transparency and enforcement in voluntary carbon credit markets (VCCMs). VCCMs are...more

CFTC Proposes to Amend Customer Funds Investment Rule Including to Again Permit Investments in Certain Non-US Sovereign Debt

The Commodity Futures Trading Commission (CFTC) has proposed to lessen a blanket restriction on the investment of customer funds in all non-United States sovereign debt instruments that was imposed on future commission...more

Funds NOT Immediately Available: Actions FCMs Should Take to Protect Customer Funds Deposited at Distressed Banks

As US interest rates rose in 2022, the value of bank investments in long-dated and fixed-rate bonds declined. These declines were substantial enough to render many banks economically insolvent. Depositors not inclined to...more

Block Trades, EFRPs and Assorted Other Trade Practice Issues: A Practical Guide of Current Status

With some frequency, Katten attorneys field questions from clients about exchange rules on off-exchange execution of futures and options on futures. This Advisory provides a high-level overview on this topic in connection...more

Foreign Listed Stock Index Futures and Options Approval Chart March 2021

Attached please find the updated Foreign Listed Stock Index Futures and Options Approvals Chart, current as of March 25, 2021. All prior versions are superseded and should be discarded. Please note the following developments...more

CFTC Adopts New Rules on Position Limits for Derivatives

The Commodity Futures Trading Commission (CFTC) voted to adopt new rules on position limits (Final Rules) in an open meeting on October 15. Once effective, the Final Rules will implement one of the remaining key provisions of...more

CFTC Adopts New Position Limits Requirements

On October 15, the Commodity Futures Trading Commission adopted new rules on position limits. The new rules mark an important step forward in a decade-long journey to enact one of the remaining key provisions of Title VII of...more

Initial Margin Guidance for US Swap End Users

Thanks to recent actions taken by the Commodity Futures Trading Commission (CFTC) and the five US prudential regulators responsible for the uncleared swap margin rules for bank swap dealers, most US end user participants in...more

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