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Understanding the SEC’s new security-based swap dealer regulations - What should commercial end users, funds, and other financial...

This client alert addresses three aspects of security-based swap (SBS) regulations recently issued by the Securities Exchange Commission (SEC) that are relevant to commercial end users, funds, and other financial end users:...more

Final rule: The CFTC clarifies the extraterritorial application of cross-border derivatives regulation – implications for the buy...

On 14 September 2020, the Commodity Futures Trading Commission (CFTC) published a final rule in the Federal Register entitled "Cross Border Application of the Registration Thresholds and Certain Requirements Applicable to...more

Energy and metals companies and funds beware: Your trading positions may be "limited"

On 30 January 2020 the Commodity Futures Trading Commission (CFTC) approved on a 3-2 vote proposed rules addressing position limits on speculative derivatives (Position Limits Proposal). The Position Limits Proposal has a...more

Documentation changes may be required for commercial end users, funds, and other financial end users

The new year is here and with it two important developments in the derivatives markets for nonswap dealer clients to consider. The first development is the market response to the looming discontinuation of U.S. dollar LIBOR...more

U.S. federal regulators propose making permanent threshold for swap dealer registration potentially benefitting energy companies...

Pursuant to regulations promulgated under the Dodd-Frank Act, entities that make a market in swaps, hold themselves out as dealers in swaps or regularly enter into swaps for their own accounts are required to register as swap...more

U.S. federal regulators propose amendments to swap margin regulations to clarify treatment of certain amendments to legacy swaps

The Dodd-Frank Act requires entities that engage in swap activities to either submit their swaps for clearing with a central clearinghouse or to collect and post collateral (margin) based on the daily mark-to-market exposure...more

FCA Announces Discontinuation of LIBOR

As you may know, on July 27, 2017 the UK's Financial Conduct Authority (FCA) chief executive Andrew Bailey announced that market participants should not rely on the London Interbank Offered Rate (LIBOR) being available after...more

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