Carl Kennedy on Regulatory Requirements

Confirming a Negative: CFTC Staff Issue an Advisory Clarifying When Foreign-Organized Entities Are Trading and Brokering Digital...

Derivatives market participants and exchanges can breathe a little easier now that Staff of the Market Participants Division and the Division of Market Oversight of the Commodity Futures Trading Commission (CFTC or...more

6/10/2025 / CFTC , Cross-Border Transactions , Derivatives , Digital Assets , Enforcement Actions , Financial Markets , Jurisdiction , Regulatory Oversight , Regulatory Requirements , Swaps

CFTC Staff Reminds Registered Exchanges and Clearinghouses to Evaluate and Calibrate Their Volatility Control Mechanisms

The Commodity Futures Training Commission’s (“CFTC”) Division of Market Oversight and Division of Clearing and Risk issued an advisory (the “Staff Advisory”) reminding designated contract markets (“DCMs”) and derivatives...more

6/2/2025 / Best Practices , CFTC , Derivatives , Financial Institutions , Financial Markets , Global Market , Regulatory Oversight , Regulatory Requirements , Risk Management

What the CFTC's Operating Divisions Will Consider When Making Enforcement Referrals

The three operating divisions of the CFTC (Division of Market Oversight, Market Participants Division, and the Division of Clearing and Risk, together the Operating Divisions) issued an advisory on April 17, explaining the...more

4/23/2025 / CFTC , Enforcement Actions , Financial Regulatory Reform , Materiality , Penalties , Regulatory Requirements , Regulatory Violations , Risk Management , Self-Reporting , Supervision

Financial Markets and Funds Quick Take | Issue 37

Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds....more

4/17/2025 / CFTC , Digital Assets , Financial Industry Regulatory Authority (FINRA) , Financial Markets , Investment Advisers Act of 1940 , Investment Funds , Regulatory Requirements , Securities and Exchange Commission (SEC) , Securities Regulation , Stablecoins

After 12 Enforcement Actions and 9 No-Action Letters, CFTC Staff Effectively Repeals the Pre-Trade Mid-Market Mark Disclosure...

The Commodity Futures Trading Commission's (CFTC or Commission) Market Participants Division (MPD) issued Letter 25-09, which effectively eliminates the pre-trade mid-market mark (PTMMM) disclosure requirement for uncleared...more

4/11/2025 / CFTC , Disclosure Requirements , Enforcement Actions , Financial Institutions , Financial Services Industry , No-Action Letters , Regulatory Reform , Regulatory Requirements , Securities and Exchange Commission (SEC) , Swap Dealers

CFTC Withdraws Controversial SEF Registration Staff Letter

The Division of Market Oversight (DMO) of the Commodity Futures Trading Commission (CFTC) has withdrawn its previous staff advisory letter on swap execution facility (SEF) registration requirements (Letter 21-19). ...more

4/2/2025 / CFTC , Enforcement Actions , EU , Financial Markets , Financial Regulatory Reform , Financial Services Industry , Regulatory Reform , Regulatory Requirements , UK

CFTC Acting Chairman Pham Announces Effort to Quickly Resolve Recordkeeping and Reporting Investigations and Pledges Additional...

During her keynote address at the Futures Industry Association’s International Futures Industry Conference, BOCA50, CFTC Acting Chairman Caroline D. Pham announced a new effort to encourage market participants to resolve open...more

3/12/2025 / CFTC , Civil Monetary Penalty , Enforcement Actions , Recordkeeping Requirements , Regulatory Reform , Regulatory Requirements , Reporting Requirements , Self-Reporting , Settlement

Clearer Skies Ahead: CFTC Enforcement Division's New Advisory Opens Doors for Self-Reporting and Increased Cooperation

In what is being widely viewed as a welcome breath of fresh air, the Commodity Futures Trading Commission (the Commission or CFTC) Division of Enforcement (the Division) released an advisory on February 25, detailing the...more

3/10/2025 / CFTC , Civil Monetary Penalty , Enforcement Actions , Executive Orders , Regulatory Reform , Regulatory Requirements , Risk Management , Self-Reporting , Transparency

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

1/27/2025 / Capital Markets , CFTC , Derivatives , Financial Institutions , Foreign Investment , Foreign Listed Stock Index , International Trade , Regulatory Requirements , Securities Regulation

Carl Kennedy

Katten Muchin Rosenman LLP

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