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COVID-19: CFTC Advances Regulatory Agenda Despite COVID-19 Pandemic

The Commodity Futures Trading Commission (CFTC or Commission) continues to advance its regulatory agenda amid the COVID-19 crisis. After an initial flurry of no-action letters that ameliorate compliance with a number of...more

CFTC Ends 2019 with Rulemaking Flurry

The Commodity Futures Trading Commission (CFTC or Commission) at year-end issued one final and two proposed rulemakings. The proposed rules are potentially significant for all swap market participants, and the final rules are...more

New Commission Moves Quickly on Enforcement

Within a week of the ceremonial swearing in of its last commissioner, the now fully formed Commodity Futures Trading Commission (Commission or CFTC) issued 17 enforcement orders and filed one complaint. These initial...more

Developments In CFTC Cooperation Program

Introduction - The Commodity Futures Trading Commission (CFTC or Commission) recently took several steps to further encourage cooperation with and self-reporting to the Commission’s Division of Enforcement (Division). In...more

New CFTC Enforcement Policy Encourages Self-Reporting

In January of this year, the Commodity Futures Trading Commission's (CFTC or Commission) Division of Enforcement (the Division) issued revised cooperation credit guidelines for companies, and its first-ever cooperation...more

CFTC Rewrites Recordkeeping Requirements

The Commodity Futures Trading Commission (CFTC or Commission) has significantly amended its recordkeeping requirements, a change that will affect all entities and individuals who are required to maintain books and records...more

CFTC Increases Anti-Retaliation Protections for Whistleblowers

On May 22, 2017, the Commodity Futures Trading Commission (CFTC or Commission) amended its whistleblower rules to enhance protections for whistleblowers against retaliation and assert its own authority to bring enforcement...more

SEC Issues Cybersecurity Examination Risk Alert

On September 15, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert re-emphasizing the careful scrutiny it will give to the data security practices of...more

Expanding Oversight of Active, Proprietary Trading Firms: SEC Proposes Amendments to Rule 15b9-1

Overview - On March 25, 2015, the Securities and Exchange Commission ("SEC" or "Commission") proposed an amendment to Rule 15b9-1 (the “Proposal”) under the Securities Exchange Act of 1934 ("Exchange Act") that, if...more

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