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CFTC Finalizes Position Limits Rules

On October 15, 2020, the Commodity Futures Trading Commission (CFTC) voted 3-2 to adopt new rules on speculative position limits (the Final Rule). The Final Rule will become effective 60 days after publication in the Federal...more

CFTC Amends Swap Data Reporting Rules, Creates Registration Framework for Non-US Clearing Organizations

On September 17, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved final rules amending the agency’s swap data reporting and derivatives clearing organization (DCO) registration requirements. The...more

CFTC Finalizes Cross-Border Swaps Rule

On July 23, 2020, the Commodity Futures Trading Commission (CFTC or Commission) voted 3-2 to approve a final rule (Final Rule) on the cross-border application of certain swap provisions under the Commodity Exchange Act (CEA)....more

CFTC Finalizes Post-Trade Name Give-Up Rule, Introduces New Electronic Trading Proposal

On June 25, 2020, the Commodity Futures Trading Commission (CFTC or Commission) held an open meeting and voted unanimously to approve a final rule prohibiting post-trade name give-up for swaps executed anonymously on a swap...more

COVID-19: CFTC Issues No-Action Relief for Market Participants

On March 17, 2020, in response to the COVID-19 (coronavirus) pandemic, the Commodity Futures Trading Commission (CFTC) Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) issued...more

CFTC Proposes New Rules on Position Limits

On January 30, 2020, the Commodity Futures Trading Commission (CFTC or Commission) voted 3-2 to issue a proposed rulemaking on speculative position limits (the Proposal). The Proposal would apply spot month-only federal...more

CFTC Proposes To Ease Certain Swap Execution Facility Rules

On January 30, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved proposed amendments (SEF Proposed Rules) to CFTC regulations related to the execution of package transactions, the correction of error...more

Ninth Circuit Holds CFTC Dodd-Frank Enforcement Authority Allows Fraud-Only Claims

On July 25, 2019, the Ninth Circuit reinstated the Commodity Futures Trading Commission’s (CFTC) lawsuit in CFTC v. Monex Credit Co.,1 interpreting the CFTC’s Dodd-Frank enforcement authority under Commodity Exchange Act...more

Skadden's 2019 Insights: Significant Regulatory, Jurisdictional and Enforcement Challenges Ahead for CFTC

In 2018, the Commodity Futures Trading Commission (CFTC or Commission) began operating with a full complement of five commissioners for the first time since 2014. Soon thereafter, it held a rare open meeting to propose major...more

Recent Court Decisions Shine Spotlight on Scope of CFTC’s Dodd-Frank Anti-Fraud and Anti-Manipulation Enforcement Authority

Recent federal court decisions, and a pending appeal in the Ninth Circuit, highlight disagreement among the courts as to the scope of the Commodity Futures Trading Commission’s (CFTC) anti-fraud and anti-manipulation...more

IBOR Global Benchmark Transition Report Finds Gap Between Awareness and Action

On June 25, 2018, the International Swaps and Derivatives Association (ISDA) and other trade associations published a report on the results of a survey of market participant preparedness for the anticipated global transition...more

CFTC and DOJ File a Flurry of Spoofing Actions

On January 29, 2018, the Commodity Futures Trading Commission (CFTC) announced the filing of eight anti-spoofing enforcement actions: three settlements with financial institutions and five complaints filed in federal district...more

LIBOR Replacement Plans Bring Regulatory Considerations for Derivatives

Plans to end the long reign of the London Interbank Offered Rate (LIBOR) as one of the world's most often-used interest rate benchmarks have recently been confirmed by several top financial regulators. On July 27, 2017,...more

"Regulators Provide Some Flexibility on the Swaps Variation Margin Compliance Deadline"

On February 23, 2017, U.S. federal banking regulators (Prudential Regulators), European regulators and the International Organization of Securities Commissions (IOSCO) issued statements clarifying their expectations on...more

"House Bill to Shake Up CFTC Rulemakings"

Less than two weeks into the new congressional session, the U.S. House of Representatives passed by a vote of 239 to 182 the Commodity End-User Relief Act1 (the Bill or House Bill), marking the first step by the new...more

"CFTC Proposes Rules to Count Cross-Border Swaps for Swap-Dealer Thresholds and Other Requirements"

The CFTC’s newly proposed rules on cross-border transactions address which swap activities affect swap-dealer thresholds and trigger transaction-level swap requirements. These are the latest in a series of CFTC rulemakings,...more

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