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Commodities Futures Trading Commission › End-Users

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
Moore & Van Allen PLLC

UPDATED: Term SOFR vs BSBY vs Ameribor in the Loan Market

Moore & Van Allen PLLC on

This is an update to a previous post. This update highlights the formal endorsement of Term SOFR by the ARRC, expands the discussion to include Ameribor and dives more deeply into the issues associated with Term SOFR swaps...more

Moore & Van Allen PLLC

Term SOFR vs BSBY in the Loan Market

Moore & Van Allen PLLC on

Wednesday, the ARRC announced (HERE) the expectation to endorse CME’s Term SOFR in late July or early August. One of the bigger pieces to this announcement is the announcement that U.S. regulators will also permit Term SOFR...more

Hogan Lovells

Derivatives: The year ahead for U.S. commercial end users, funds, and other financial end users

Hogan Lovells on

With 2020 now behind us, we look forward to the year ahead while noting just one of the many lessons of the past year: the difficulty of prediction. We simplify the task by limiting our focus to five topics in derivatives...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Updates LIBOR Transition Relief

Skadden, Arps, Slate, Meagher & Flom LLP on

On August 31, 2020, the Commodity Futures Trading Commission (CFTC or Commission) announced relief for swap dealers (SD) and other market participants related to the industry-wide transition from swaps that reference the...more

Kramer Levin Naftalis & Frankel LLP

Decoding Derivatives - Q4 2019

Kramer Levin Naftalis & Frankel LLP on

Thomas Cook Takeaways - For credit default swap (CDS) protection buyers with protection on Thomas Cook Group Plc,  a U.K. scheme of arrangement paving the way for a £1.6 billion debt-to-equity exchange imposed on all debt...more

Skadden, Arps, Slate, Meagher & Flom LLP

Final Phases of Initial Margin Requirements for Uncleared Swaps Expected to Spark Additional Margin Compliance Efforts

Skadden, Arps, Slate, Meagher & Flom LLP on

On July 19, 2018, the International Swaps and Derivatives Association (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) published a white paper entitled "Initial Margin for Non-Centrally Cleared...more

Moore & Van Allen PLLC

The Transition Away From USD LIBOR for Swaps - A Report for U.S. Market Participants

Moore & Van Allen PLLC on

With the Financial Conduct Authority (the “FCA”) announcing in July 2017, essentially, its intent to no longer persuade or compel panel banks to make LIBOR submissions by the end of 2021, the future of LIBOR, and its role in...more

Troutman Pepper

Documentation for the New Swap Margin Rules and Thoughts for the Buy Side and End Users

Troutman Pepper on

Because of the implementation of new regulatory requirements relating to both variation and initial margin for swaps, swap documentation for many market participants is about to become much more complicated....more

Skadden, Arps, Slate, Meagher & Flom LLP

"Non-Cleared Swap Variation Margin Requirements to Spark Credit Support Annex Amendments for Financial End Users"

Skadden, Arps, Slate, Meagher & Flom LLP on

On March 1, 2017, new rules adopted by U.S. Prudential Regulators and the Commodity Futures Trading Commission (CFTC) will require registered swap dealers to post and collect daily variation margin for over-the-counter,...more

Holland & Knight LLP

Guide to U.S. Variation Margin Documentation for Financial End Users

Holland & Knight LLP on

The scheduled implementation date applicable for most financial end users for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules is March 1, 2017. In most cases, the U.S....more

McGuireWoods LLP

ISDA Launches 2016 Variation Margin Protocol to Facilitate Compliance With Margin Rules

McGuireWoods LLP on

On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol will help market participants implement the new variation...more

Cadwalader, Wickersham & Taft LLP

CFTC Unanimously Approves Supplemental Proposal on Position Limits

Cadwalader, Wickersham & Taft LLP on

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

Orrick, Herrington & Sutcliffe LLP

Derivatives in Review - April 2016

Orrick, Herrington & Sutcliffe LLP on

Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Eliminates End-User Trade Option Reporting Requirements and Addresses Applicability of Position Limits"

Skadden, Arps, Slate, Meagher & Flom LLP on

The Commodity Futures Trading Commission (CFTC or Commission) adopted a final rule effective March 21, 2016, that eliminates the reporting and recordkeeping requirements under the CFTC’s existing trade option exemption for...more

Morrison & Foerster LLP

CFTC Finalizes Relief from Trade Option Reporting and Recordkeeping Requirements for Commercial End Users

Morrison & Foerster LLP on

On March 16, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) approved a final rule that eliminates the reporting and recordkeeping requirements in current CFTC regulations for trade option counterparties that are...more

Orrick - Finance 20/20

CFTC Approves Final Rule to Amend the Trade Option Exemption by Eliminating Certain Reporting and Recordkeeping Requirements for...

Orrick - Finance 20/20 on

On March 16, the U.S. Commodity Futures Trading Commission approved a final rule that eliminated certain requirements “for trade option counterparties that are neither swap dealers nor major swap participants[.]”...more

Cadwalader, Wickersham & Taft LLP

CFTC Adopts Final Trade Option Rule

Cadwalader, Wickersham & Taft LLP on

On March 16, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved amendments to the rules applicable to certain physically-settled options referred to as “trade options.” This final rule substantially...more

Stinson - Corporate & Securities Law Blog

CFTC Eliminates Certain Trade Option Reporting and Recordkeeping Requirements for End Users

Stinson - Corporate & Securities Law Blog on

The CFTC approved a final rule today that removes trade option* reporting and recordkeeping requirements applicable to non-swap dealer/major swap participant counterparties (“Non-SD/MSPs” or “end users” for purposes of this...more

McGuireWoods LLP

Financial Entity Update: The CFTC’s Proposed Margin Rules for Uncleared Swaps – Goofy Haircut

McGuireWoods LLP on

Under the Margin Rules, swap dealers and major swap participants that do not have a prudential regulator (Covered Swap Entities, or CSEs) would be required to collect and post initial margin for uncleared swaps with financial...more

McGuireWoods LLP

Financial Entity Update: The CFTC’s Proposed Margin Rules for Uncleared Swaps – Know Thyself

McGuireWoods LLP on

To clarify our intended audience, in the Financial Entity Update we will address issues germane to entities that trade swaps but are neither dealers nor commercial end users. This includes a broad and diverse group of...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Derivatives in Review - June 2015

Orrick, Herrington & Sutcliffe LLP on

NYDFS Finalizes BitLicense Regulations - On June 3, 2015, the New York Department of Financial Services released its final BitLicense regulations, which it described as "the first comprehensive framework for regulating...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on

EBA Final Report on Guidelines on Triggers for Use of Early Intervention Measures Under BRRD - On May 8, the European Banking Authority (EBA) published its final report (EBA/GL/2015/03) on guidelines on triggers for the...more

McGuireWoods LLP

Swaps End-User Update CFTC Proposes Reporting and Recordkeeping Relief for Commodity Trade Options

McGuireWoods LLP on

On April 30, 2015, the U.S. Commodity Futures Trading Commission (CFTC) approved a notice of proposed rulemaking (Proposed Rules) to reduce reporting and recordkeeping obligations for end-users that use commodity trade...more

Stinson - Corporate & Securities Law Blog

CFTC Proposes Changes to Trade Option Rules for End Users

Stinson - Corporate & Securities Law Blog on

The CFTC has proposed several important changes that would alleviate the reporting and recordkeeping obligations of end users with respect to trade options (or provide by rule certain relief currently only available under...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Proposes to Reduce Trade Option Reporting Requirements for Commercial End-Users"

Skadden, Arps, Slate, Meagher & Flom LLP on

Trade options are physically settled over-the-counter options on most deliverable commodities (e.g., agricultural, energy, or metals) where the buyer is a producer, processor, commercial user or merchant of the commodity...more

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