On 28 October 2020, the U.S. Securities and Exchange Commission adopted Rule 18f-4 under the Investment Company Act of 1940, as amended. The rule replaces the SEC’s decades-old patchwork of guidance with a comprehensive...more
I. INTRODUCTION -
The Commodity Futures Trading Commission (“CFTC” or “Commission”) recently approved a proposed rule (the “Proposed Rule”) to improve the regulation of cross-border swap transactions and establish a formal...more
AGENDA -
- Global Derivatives Regulatory Update
- Margin for Uncleared Swaps
- EMIR REFIT
- FINRA Rule 4210 Margin Requirements
CFTC Regulatory Developments -
- NFA Compliance Rule 2-9
- NFA Compliance Rule 2-29
-...more
Changes to the MiFID II regulatory regime will impose new obligations on many global investment managers that, to date, have avoided substantive regulation in the European Union ("EU"). While the precise scope of these...more
As previously noted in the client alert “Brexit: A First Look at the Impact on Asset Managers That Trade Derivatives,” Brexit is not anticipated to have an immediate impact on ISDA Documentation or derivatives contracts. ...more
Asset managers and investment funds that make significant use of derivatives will face regulatory and operational challenges in the post-Brexit vote environment. Although the Brexit vote is not expected to have an immediate...more