On April 21, 2025, Commodity Futures Trading Commission (“CFTC”) staff issued two Requests for Comment (“RFCs”) aimed at gathering public input on emerging areas of interest in the derivatives markets....more
Coming off a busy 2024, we expect that 2025 will be a landmark year for the Commodity Futures Trading Commission (CFTC or Commission). Rostin Behnam’s resignation as Chairman on January 20 marked the end of the Biden...more
3/11/2025
/ Artificial Intelligence ,
Biden Administration ,
CFTC ,
Decentralized Finance (DeFi) ,
Derivatives ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Executive Orders ,
Final Rules ,
Financial Institutions ,
Financial Markets ,
Proposed Rules ,
Regulatory Agenda ,
Trump Administration
The CFTC has seen a significant amount of activity since the inauguration of President Donald Trump on January 20. Chairman Rostin Behnam resigned as Chairman and as a Commissioner. Caroline Pham was elected Acting Chairman...more
2/27/2025
/ Artificial Intelligence ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Derivatives ,
Digital Assets ,
Enforcement Actions ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Swap Dealers
With the Presidential and Congressional transitions taking place this month, we expect increased investment and transactional activity in capital markets. This will likely include trading platforms, exchanges, clearinghouses,...more
2/6/2025
/ Asset Management ,
Broker-Dealer ,
Capital Markets ,
CFTC ,
Commodities ,
Derivatives ,
Due Diligence ,
Financial Services Industry ,
Futures ,
Investment Adviser ,
Investment Management ,
Trading Platforms
A new president, coupled with Republican control of the U.S. Senate and the U.S. House of Representatives — with a number of House races still pending — will fundamentally alter the operation of the executive branch and...more
11/22/2024
/ Administrative Agencies ,
CFTC ,
Congressional Committees ,
Congressional Review Act ,
Election Results ,
Legislative Agendas ,
Political Parties ,
Presidential Appointments ,
Public Policy ,
Regulatory Agenda ,
Rulemaking Process ,
Trump Administration
Until recently, the Commodity Futures Trading Commission (CFTC) has limited the ability of US persons to participate in election markets. However, recent developments have allowed event contracts to be made available to US...more
On September 19, 2024, the Commodity Futures Trading Commission (CFTC) approved final guidance regarding the listing of voluntary carbon credit (VCC) derivative contracts (the Final Guidance). The Final Guidance—which...more
As we have previously noted, the Commodity Futures Trading Commission (CFTC) continues to face legal challenges to its regulatory approach to political event contracts. The past two weeks have seen a flurry of activity in the...more
On May 10, 2024, the Commodity Futures Trading Commission (CFTC or Commission) proposed amendments to CFTC Regulation 40.11 (the Proposed Rule) that further define “gaming” contracts considered “contrary to the public...more