Jill Sommers Reflects on the CFTC, Dodd-Frank, and Her Future
- Federal spot month limits would expand to cover 25 physical commodity futures, as well as certain “look alike” contracts and OTC swaps on the same underlying commodity. - Limits generally would be set at higher levels...more
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
At its open meeting held on January 30, 2020, the Commodity Futures Trading Commission (“CFTC” or “the Commission”) approved a proposed rulemaking to institute federal position limits in an effort to prevent excessive...more
Will the fourth time be the charm? This week, the Commodity Futures Trading Commission will try for the fourth time since 2011 to revise its speculative position limits rules. Details have not been made public, but Heath...more
On August 20, 2019, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) adopted final regulations (the “Amended Final Regulations”) revamping the regulations...more
The CFTC has published a proposed supplement to its December 2013 proposed rule on position limits* that would, among other things, authorize designated contract markets and swap execution facilities (“exchanges”) to...more
On May 26, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved a proposed supplement (“Supplemental Proposal”) to its December 2013 proposal to establish position limits on futures and economically...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
On October 12, CFTC Staff Interpretive Letter 12-19 provided guidance with respect to the interpretation of bona fide hedging under CFTC Regulations. Under Rule 4.5 of the CFTC’s Regulations, advisers may be excluded from the...more
In light of the numerous regulatory changes triggered by the definition of “swap” taking effect on October 12, Commodity Futures Trading Commission staff released a series of no-action letters and interpretations late last...more
On October 12, the CFTC released a number of no-action letters and interpretive guidance addressing: - Swap calculation by certain foreign entities for purposes of the swap dealer and major swap participant...more
On September 28, 2012, Judge Robert Wilkins of the U.S. District Court for the District of Columbia granted the summary judgment motion of the International Swaps and Derivatives Association and Securities Industry and...more