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CFTC Grants No-Action Relief to Commodity Pool Operators with Respect to Certain Insurance-Linked Securitization Vehicles

Toward the end of 2014, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued two letters affecting insurance-linked securitization vehicles: CFTC...more

1/19/2015  /  CFTC , CPOs , DSIO , No-Action Relief , SIFMA , Swap Dealers , Swaps

Congress Exempts Non-Financial End-Users, Their Agents and Certain Cooperatives From Non-Cleared Swap Margin Requirements in...

On January 8, 2015, the U.S. Senate approved legislation, by a 93-4 vote, to reauthorize the Terrorism Risk Insurance Act (“TRIA”). The legislation, dubbed the Terrorism Risk Insurance Program Reauthorization Act of 2015 (the...more

CFTC Expands Existing Clearing Relief for Treasury Affiliates

On November 24, the Commodity Futures Trading Commission’s (CFTC) Division of Clearing and Risk (DCR) issued a no-action letter to expand previously issued relief, that is available to “treasury affiliates,” from the...more

An End-User's Guide to the CFTC's Final Cross-Border Guidance

Last month, the U.S. Commodity Futures Trading Commission (CFTC) issued final interpretive guidance with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank...more

Legal Alert: Nearly at the Buzzer, CFTC Affords End-Users Relief from Dodd-Frank Reporting Requirements

On the brink of the compliance date for arguably one of the most burdensome requirements that end-users face under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Commodity Futures Trading...more

Legal Alert: ISDA Accepting Comments on Draft Dodd-Frank "Protocol 2.0"

Pursuant to Title VII of the Dodd-Frank Wall Street Reform and Customer Protection Act (Dodd-Frank), the Commodity Futures Trading Commission (CFTC) has adopted a number of final regulations that require swap dealers (SDs)...more

Legal Alert: The CPO and CTA Regulatory Regimes: What Operators of and Advisers to Commodity Pools Should Expect in 2013

There were a number of significant changes to the regulatory regime for commodity pool operators (CPOs) and commodity trading advisors (CTAs) in 2012. As a result of these changes, various types of collective investment...more

CFTC Announces Beginning of Real-Time Reporting and Swap Dealer Registration Requirements and Releases List of Provisionally...

Today, Wednesday, January 2, 2013, the Commodity Futures Trading Commission (CFTC) announced that final rules pertaining to: (1) real-time reporting of swap transaction data; and (2) swap dealer registration requirements,...more

1/3/2013  /  CFTC , Registration , Swap Dealers , Swaps
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