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National Futures Association Proposes New Reporting Requirements for Commodity Pool Operators

The National Futures Association (NFA) has proposed a new rule that would require registered commodity pool operators (CPOs) that are members of the NFA (CPO Members) to report to the NFA by 5:00 pm Central Time the next...more

CFTC Amends Real-Time Swap Public Reporting Requirements

The Commodity Futures Trading Commission (CFTC) has unanimously approved amendments to the real-time swap reporting rules in Part 43 of the CFTC’s regulations by, among other things, clarifying the applicability of the rules...more

Final CFTC Rules Prohibit Post–Trade Name Give-Up for Swaps

The US Commodity Futures Trading Commission adopted final rules on June 25 prohibiting post–trade name give-up for anonymously executed and intended-to-be-cleared swaps effected on swap execution facilities....more

CFTC Delays Phase 5 Initial Margin Implementation Date

The US Commodity Futures Trading Commission has approved an interim final rule extending the Phase 5 initial margin compliance deadline for uncleared swaps by one year....more

Global Standard Setters Extend Deadlines for Uncleared Margin Requirements

To help address market participants in the face of the coronavirus (COVID-19) crisis, the Basel Committee on Banking Supervision and the International Organization of Securities Commissions have provided a one-year extension...more

CFTC No-Action Relief for Registrant and Market Participant COVID-19 Response

Many Commodity Futures Trading Commission registrants and other market participants are responding to the coronavirus (COVID-19) pandemic by implementing business continuity plans that move personnel from their “normal...more

Latest CFTC Position Limits Proposal: If At First You Don't Succeed, Try, Try Again

After a decade of rulemaking efforts, the Commodity Futures Trading Commission is proposing revisions to its regulations concerning federal speculative position limits to conform to the Wall Street Transparency and...more

The Commodity Futures Trading Commission's Swaps Cross-border Guidance Proposal

The Dodd-Frank Act amended the Commodity Exchange Act (the Act) to create a new regulatory framework for swaps, and added Section 2(i) to require the application of the Dodd-Frank Act swap requirements to activities that...more

CFTC Staff Clarifies Registration Relief Available to Non-US Asset Managers

No-action relief confirms that non-US asset managers may rely on an exemption from CFTC registration when trading uncleared swaps in the United States for the accounts of their non-US clients, an issue that had been in doubt...more

CFTC Releases No-Action Letter 14-144

The letter modifies previous No-Action Letter 13-22, to expand relief for treasury affiliates entering into swaps on behalf of non-financial end-user affiliates that could otherwise elect the exception in section 2(h)(7) of...more

SEC Permits Portfolio Margining of Credit Default Swaps

Order grants exemptive relief from Exchange Act requirements; parallel CFTC relief expected soon. On December 14, the Securities and Exchange Commission (SEC) issued an order granting exemptive relief (Exemptive Order)...more

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