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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

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

Expected CFTC Implementations Post-2024 Election: Key Considerations for Futures Commission Merchants

The 2024 US elections may signal a shift in the policy orientation of other federal financial regulators, but at the Commodity Futures Trading Commission (CFTC or Commission), at least in the short-term, the most significant...more

The CFTC's Updated Block and Cap Sizes for 2024

The Division of Data (DOD) of the Commodity Futures Trading Commission (CFTC or the Commission) published updated post-initial appropriate minimum block sizes and post-initial cap sizes under Part 43 of the CFTC’s...more

The CFTC Adopts Amendments to Capital and Financial Reporting Requirements for Swap Dealers Largely Based on Prior Relief

After adopting final rules in 2020, the Commodity Futures Trading Commission (CFTC) adopted amendments to the capital and financial reporting requirements for Swap Dealers (SDs), which were largely based on prior no-action...more

The CFTC Proposes Operational Resiliency Rules for FCMs, Swap Dealers and Major Swap Participants

Adopted partially in response to a 2023 cyberattack on a widely-used, third-party service provider to several financial services firms, the Commodity Futures Trading Commission (CFTC) has proposed new requirements and...more

"Let's Talk About Risk," Says CFTC in an Advanced Notice of Proposed Rulemaking

Current risk management program (RMP) requirements of swap dealers (SDs) and future commission merchants (FCMs) will be re-evaluated as part of an advanced notice of proposed rulemaking (ANPRM) issued by the Commodity Futures...more

6/8/2023  /  CFTC , Risk Management , Swap Dealers

A Promise Made, a Promise Kept: CFTC Adopts Final Cross-Border Swaps Rules Largely as Proposed

KEY POINTS - - The Commodity Futures Trading Commission (CFTC) has finalized its proposed new rule (Final Rule) relating to the cross-border application of certain of its swap regulations. - The Final Rule supersedes...more

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