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Federal Judge Upholds CFTC’s Determination that Virtual Currencies Are Commodities

In September 2015, the Commodity Futures Trading Commission (CFTC) stated in a settlement order that “Bitcoin and other virtual currencies are encompassed in the definition and properly defined as commodities” under the...more

CFTC Finalizes Relief from Trade Option Reporting and Recordkeeping Requirements for Commercial End Users

On March 16, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) approved a final rule that eliminates the reporting and recordkeeping requirements in current CFTC regulations for trade option counterparties that are...more

CFTC Staff Issues No-Action Relief from Mandatory Swaps Clearing for Small Bank Holding Companies, Small Savings and Loan Holding...

On January 8, 2016, the Division of Clearing and Risk (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters providing relief from the mandatory clearing requirement for swaps under Section...more

CFTC Proposes Regulation of Automated Trading

On November 24, 2015, the Commodity Futures Trading Commission (“CFTC”) approved the issuance of proposed rules to implement a framework of registration, reporting, recordkeeping and other compliance requirements for market...more

CFTC Requires Introducing Brokers, Commodity Pool Operators, and Most Commodity Trading Advisors That Use Swaps to Become Members...

On September 14, 2015, the Commodity Futures Trading Commission (CFTC) published a final rule requiring introducing brokers (IBs), commodity pool operators (CPOs), and most commodity trading advisors (CTAs) to become members...more

CFTC and SEC Propose Interpretation Concerning Forward Contracts with Embedded Volumetric Optionality

On November 13, 2014, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) approved for publication in the Federal Register a proposed interpretation clarifying the CFTC’s...more

CFTC Staff Issues Commodity Option Frequently Asked Questions (“FAQs”)

On September 30, 2013, the CFTC’s Division of Market Oversight (“DMO”) issued a Commodity Option FAQ document. While the document largely contains information already set forth in prior CFTC releases, it does contain helpful...more

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