The Commodity Futures Trading Commission, under a reconstituted Commission, is signaling a new era of aggressive enforcement of the Commodity Exchange Act.
Significant Violations and Penalties -
United States-
On...more
According to government regulators across the globe, everyone should have been acting to slow USD LIBOR use for the next six weeks. Except, of course, for the next six weeks…
UK FCA Announcement-
It is now official –...more
Snidely Whiplash kidnaps Nell and, in the show’s opening, ties her to the railroad tracks to get even with his nemesis, Dudley Do-Right, of the famed Royal Canadian Mounted Police. Menacing music plays.
In each episode,...more
11/4/2021
/ Alternative Reference Rates Committee (ARRC) ,
CFTC ,
Comptroller ,
Consumer Financial Protection Bureau (CFPB) ,
FDIC ,
Federal Reserve ,
Financial Conduct Authority (FCA) ,
Interest Rates ,
ISDA ,
Libor ,
NCUA ,
Proposed Legislation ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Trust Indenture Act ,
UK
As part of the ongoing transition from the London InterBank Offering Rate (LIBOR) to the Secured Overnight Financing Rate (SOFR) recommended by the Alternative Reference Rates Committee (ARRC) as an alternative rate, an...more
6/15/2021
/ Alternative Reference Rates Committee (ARRC) ,
CFTC ,
FDIC ,
Financial Institutions ,
Interest Rates ,
ISDA ,
Libor ,
OCC ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Sterling Overnight Index Average (SONIA) ,
UK
The United Kingdom’s Financial Conduct Authority announced the future cessation and loss of representativeness of worldwide LIBOR rates.
Potential Detrimental Developments -
Recent Events -
On Friday, March 5,...more
3/11/2021
/ Alternative Reference Rates Committee (ARRC) ,
CFTC ,
Department of Justice (DOJ) ,
FBI ,
Financial Conduct Authority (FCA) ,
Fraud ,
Interest Rates ,
ISDA ,
Libor ,
New York ,
NYDFS ,
OCC ,
Proposed Legislation ,
Securities and Exchange Commission (SEC) ,
Transitional Arrangements ,
UK
In recent years, the Commodity Futures Trading Commission (CFTC) filed two actions with facts so shocking the reader is forced to ask, ‘can this be how the industry really functions?’
The Complaints -
The most recent...more
2/24/2021
/ CFTC ,
Commodity Exchange Act (CEA) ,
Dodd-Frank ,
Fraud ,
Libor ,
Material Disclosures ,
MSRB ,
Price Manipulation ,
Securities and Exchange Commission (SEC) ,
Suitability Requirements ,
Swaps
On August 4, 2020, the Commodity Futures Trading Commission (the “CFTC”) announced that the Honorable Vernon S. Broderick of the U.S. District Court for the Southern District of New York entered a Consent Order approving a...more
Previous Repos -
In the last Client Alert, it was reported that the New York Fed recently infused approximately $220 billion into the banking system – $70 billion of overnight repos and $150 billion in term repos....more
12/30/2019
/ Banking Sector ,
CFTC ,
Enforcement Actions ,
Federal Reserve ,
FOMC ,
Interest Rates ,
Libor ,
Liquidity ,
Market Manipulation ,
Secured Overnight Funding Rate (SOFR) ,
Swaps