On April 29, 2015, the Securities and Exchange Commission (SEC) proposed new rules1 that would address how registration, SEC Regulation SBSR and other SEC requirements for security-based swap transactions would apply to a...more
Last week, the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief that provides chief compliance officers (CCOs) of registered swap dealers (SDs),...more
The Securities and Exchange Commission (SEC) recently issued three releases with final and proposed regulations addressing the reporting of security-based swaps (SB swaps) called for by the Dodd-Frank Act. The regulations...more
As the Commodity Futures Trading Commission (CFTC) completes the derivatives regulations mandated by the Dodd-Frank Act, the European Union continues to develop its own derivatives rules. Both sets of regulations seek to...more
Annual Report Advisory -
On December 22, 2014, the Division of Swap Dealer and Intermediary Oversight (Division) of the U.S. Commodity Futures Trading Commission (CFTC) released an advisory (Advisory) providing...more
On December 16, 2014, President Barack Obama signed into law a bill that lessens the impact of Section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, more commonly known as the “Swaps Push-Out...more
On November 3, 2014, the Commodity Futures Trading Commission (CFTC or Commission) approved three proposals that Chairman Timothy Massad described as “fine tuning” certain of the CFTC’s rules “to make sure they do not impose...more
Federal banking regulators (the Prudential Regulators) have re-proposed regulations to require certain dealers and major participants in the swap and security-based swap markets to collect initial and variation margin for...more
The Commodity Futures Trading Commission (Commission or CFTC) has further extended the comment periods for its November 2013 proposal concerning position limits aggregation and its December 2013 proposal concerning position...more
On June 25, 2014, the Securities and Exchange Commission (SEC) adopted the first of a series of rules and guidance that will establish how security-based (SB) swap requirements under the Dodd-Frank Wall Street Reform and...more
On May 2, 2014, the Securities and Exchange Commission (SEC)published in the Federal Register proposed regulations1 that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street...more
On May 22, 2014, the Commodity Futures Trading Commission (Commission or CFTC) and its staff took three actions.
First, the Commission proposed to amend its existing definition of “swap dealer” in order to allow...more
On May 15, 2014, the International Swaps and Derivatives Association (ISDA) and the Futures Industry Association (FIA) Europe published the ISDA/FIA Europe Cleared Derivatives Execution Agreement (ISDA/FIA Europe CDEA). ...more
On April 17, 2014, the Securities and Exchange Commission (SEC) proposed new regulations that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street Reform and Consumer...more
Market participants that enter into uncleared swaps should expect to receive notifications from swap dealer (SD) and major swap participant (MSP) counterparties regarding segregation of initial margin for swaps. Dodd-Frank...more
As of February 15, 2014, certain types of fixed-for-floating interest rate swaps must be executed on a swap execution facility (SEF) or a designated contract market (DCM), unless an exception applies (e.g., the commercial...more
The European Market Infrastructure Regulation (EMIR) requires EU-counterparties to all derivative contracts, whether traded on- or off-exchange, to report certain information and details relating to the trade to a registered...more
The Commodity Futures Trading Commission (CFTC) announced that the Global Markets Advisory Committee (GMAC) will hold a public meeting on February 12, 2014, to discuss CFTC Staff Advisory 13-69 (Staff Advisory)....more
Since the enactment of Dodd-Frank in 2010, the CFTC and the SEC have proceeded at different speeds to address previously unregulated markets for swaps and security-based swaps, respectively. The CFTC moved quickly to develop...more
In October 2013, the Commodity Futures Trading Commission used enforcement powers it gained under the Dodd-Frank Act in an order finding that a major financial institution recklessly employed manipulative devices in trading...more
On January 16, 2014, staff of the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (Division) announced that the first “made-available-to-trade” determination (MAT Determination) will become...more
In 2013, the Commodity Futures Trading Commission (CFTC) adopted final guidance describing the circumstances in which the Dodd-Frank Act requirements will apply to cross-border swap activities (Guidance). In conjunction with...more
On November 5, 2013, the Commodity Futures Trading Commission (CFTC) voted 3-1 to re-propose rules to establish speculative position limits for futures, options and economically equivalent swaps on certain agricultural, metal...more
Earlier this year, the Commodity Futures Trading Commission (CFTC) issued Cross-Border Guidance that set out the agency’s interpretation on the extent to which CFTC swap regulations would apply outside the U.S. The...more
On December 10, 2013, five U.S. financial regulators (the Agencies) adopted a final rule implementing the Volcker Rule. The text of the final rule and its accompanying preamble are available here. The Volcker Rule was created...more
12/12/2013
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Volcker Rule