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CFTC 2022 Enforcement and Regulatory Developments and a Look Forward

The year 2022 was a historic year for the Commodity Futures Trading Commission (“CFTC” or the “Commission”). Just four days into the new year, on January 4, 2022, Rostin Behnam was sworn in as the CFTC’s 15th Chairman. Three...more

Developments In CFTC Cooperation Program

Introduction - The Commodity Futures Trading Commission (CFTC or Commission) recently took several steps to further encourage cooperation with and self-reporting to the Commission’s Division of Enforcement (Division). In...more

2017 CFTC Year-in-Review and a Look Forward

In 2017, under the leadership of new Chairman J. Christopher Giancarlo, the Commodity Futures Trading Commission (CFTC or Commission) adopted a notable shift in its enforcement priorities and regulatory agenda. In March,...more

2016 CFTC Year-in-Review and a Look Forward

In 2016, the Commodity Futures Trading Commission (CFTC or Commission) continued to pursue high-profile enforcement cases and to test its new enforcement authority under the Dodd-Frank Wall Street Reform and Consumer...more

Futures and Derivatives Alert: Update on NFA’s Swap Dealer Examinations and Upcoming Priorities

Introduction - Both the Commodity Futures Trading Commission (CFTC) and the National Futures Association (NFA), the self-regulatory organization for the US derivatives industry, have signaled their expectation—now...more

CFTC Revises Proposed Reg AT

The Commodity Futures Trading Commission (CFTC or Commission) on November 3, 2016, proposed revisions (the Supplemental Proposal) to proposed Regulation Automated Trading (Reg AT). Reg AT, if adopted, will broadly affect...more

SEC Adopts Rules on Non-US Firms That “Arrange, Negotiate, or Execute” Security-Based Swaps in the US

On Wednesday, the Securities and Exchange Commission (SEC) adopted rules that will affect firms operating in the global security-based swap market. Specifically, the SEC is requiring non-US firms that arrange, negotiate, or...more

CFTC Proposes “Regulation AT” for Automated Trading

I. Executive Summary - On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or...more

CFTC Updates Position Limits Rule

On September 22, 2015, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved the publication of a “supplemental” proposed rule on position limits. The supplemental proposal would modify the...more

SEC Proposes Rules to Oversee Non-US Firms’ Swap Activity in the United States

On April 29, 2015, the US Securities and Exchange Commission (SEC) proposed new rules to enhance its oversight of non-US firms’ security-based swap activity in the United States. The proposal, if adopted, will have important...more

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