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CFTC Issues No-Action Letters To Smooth The Road Away From The IBORs

On December 17, 2019, three different divisions of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters intended to facilitate the swaps market’s transition away from interbank offered rates (each, an...more

Structured Thoughts: News for the Financial Services Community, Volume 10, Issue 6

In this issue of Structured Thoughts, we discuss: ..European Commission consultation on EU benchmark regulation ..FINRA: Suitability and sales practices remain an issue ..SEC charges Switzerland-based dealer for selling...more

Prudential Banking Regulators Propose Amendments to Margin Rules for Non-cleared Swaps

On November 7, 2019, five U.S. prudential regulators published in the Federal Register significant amendments (including the accompanying release, the “PR Amendments”) that they are proposing to modify the margin rules (the...more

CFTC Proposes Rules to Delay Compliance Date for Initial Margin for Swaps with Certain Smaller Financial End Users

On October 16, 2019, the Commodity Futures Trading Commission (CFTC) proposed rules that, if finalized, would delay by one year the date by which swap dealers must comply with the CFTC’s initial margin (IM) requirements in...more

Structured Thoughts: News for the Financial Services Community, Volume 10, Issue 4

In this issue of Structured Thoughts, we discuss: ..The SEC’s newly released margin rules for security-based swap dealers. ..U.K.’s Financial Conduct Authority consultation on its proposal to ban the sale, marketing, and...more

CFTC Chairman Issues White Paper Outlining Agenda for Changes to Swaps Regulation

On April 26, 2018, J. Christopher Giancarlo, Chairman of the Commodity Futures Trading Commission (“CFTC” or “Commission”) and Bruce Tuckman, the CFTC’s Chief Economist, issued a white paper outlining changes to swaps...more

The SEC’s Final Rule Regarding Price Quotes and Research Reports Relating to Security-Based Swaps

This month the Securities and Exchange Commission (“SEC”) issued a final rule (the “Final Rule”) that provides that certain communications relating to security-based swaps (either singular or plural, “SBS”) will not...more

CFTC Order Extends Application of Current De Minimis Threshold Until December 2019

Last week the Commodity Futures Trading Commission (“CFTC”) issued an order (the “De Minimis Order”) that pushes back by one year the date on which the CFTC may lower its swap dealer de minimis threshold, the amount of swap...more

The Federal Reserve and OCC Guidance Regarding Initial Examinations for Compliance with Variation Margin Rules for Non-Cleared...

Last week the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and the Office of the Comptroller of the Currency (the “OCC” and, collectively with the Federal Reserve, the “Banking Agencies”) released...more

CFTC Releases Its Final Staff Report on the Swap Dealer De Minimis Exception

Last month the Commodity Futures Trading Commission (“CFTC”) released the final report of its staff (the “Staff”) on the de minimis exception to the CFTC’s definition of “swap dealer” (the “Final Report”). That exception,...more

A step closer - The SEC still has some work to do to finalise its framework for SBS dealer registration but firms are already...

More than six years after the enactment of the Dodd-Frank Act, and more than three years after the US Commodity Futures Trading Commission (CTFC) required swap dealers to register in accordance with Title VII of that Act, it...more

SEC Issues Business Conduct Rules for Security-Based Swap Entities

In an important step in the ongoing regulation of the market for security-based swaps (both individually and in the plural, “SBS”), last month the Securities and Exchange Commission (“SEC”) issued its final business conduct...more

Margin for Uncleared Swaps: A Critical Look at the CFTC and Prudential Regulators Proposals

Last fall both the Commodity Futures Trading Commission (“CFTC”) and five U.S. prudential banking regulators (the “Prudential Regulators”) released proposed rules for margin requirements for uncleared swap transactions for...more

2/23/2015  /  CFTC , IOSCO , Swap Dealers , Swap Market , Swaps
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