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Commodities Futures Trading Commission No-Action Letters

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 -

Investment Services Regulatory Update - November 2017

by Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more

The Treasury Report’s Recommendations for Derivatives Regulation

by Morrison & Foerster LLP on

In a previous client alert we provided an overview of the recent report, the second of four, issued by the U.S. Department of the Treasury (“Treasury”) and titled “A Financial System that Creates Economic Opportunities,...more

CFTC’s Division of Market Oversight Extends Existing Relief and Provides Additional Relief for Reporting Parties From Reporting...

On September 25, 2017, the Division of Market Oversight of the U.S. Commodity Futures Trading Commission “issued a no-action letter (CFTC Staff Letter 17-45) that extends current relief and provides additional relief to...more

Financial Services Weekly News - September 2017 #3

by Goodwin on

Editor's Note - Cybersecurity Returns to Center Stage. The Equifax breach and recent news that the Securities and Exchange Commission’s (SEC) EDGAR test filing system was hacked in 2016 have brought cybersecurity back to...more

US Commodity Futures Trading Commission Staff Extends Time-Limited No-Action Relief on the Applicability of Transaction-Level...

by Shearman & Sterling LLP on

The U.S. Commodity Futures Trading Commission’s (CFTC) Divisions of Swap Dealer and Intermediary Oversight (DSIO), Clearing and Risk, and Market Oversight issued a time-limited no-action letter providing relief to certain...more

Orrick's Financial Industry Week In Review

FHFA Updates Progress on Fannie Mae and Freddie Mac Credit Risk Transfer Programs - On July 26, 2017, the Federal Housing Finance Agency released an update on the credit risk transfer programs of Freddie Mac and Fannie Mae...more

CFTC Extends No-Action Relief to SEFs and DCMs From Certain CFTC Regulations for Correction of Errors

On May 30, 2017, the U.S. Commodity Futures Trading Commission‘s (“CFTC“) Division of Market Oversight and Division of Clearing and Risk issued a no-action letter extending the relief provided in CFTC Letter No. 16-58, which...more

US Commodity Futures Trading Commission Provides Relief Associated with Swap Trade Confirmations

by Shearman & Sterling LLP on

The CFTC’s Division of Market Oversight (DMO) issued a no-action letter extending relief associated with swap trade confirmation requirements that previously was provided in CFTC Staff Letter 16-25, which expires March 31,...more

US Commodity Futures Trading Commission Provides Time-Limited No-Action Relief for Aggregation Notice Filings for Position Limits

by Shearman & Sterling LLP on

The CFTC’s Division of Market Oversight issued a time-limited no-action letter stating that, from February 14, 2017 to August 14, 2017, it will not recommend an enforcement action for failure to file a notice when relying on...more

US Commodity Futures Trading Commission Issues Time-Limited No-Action Transition for March 1, 2017 Compliance Date for Variation...

by Shearman & Sterling LLP on

US Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a time-limited no-action letter (CFTC staff letter 17-11) which provides that, from March 1, 2017 to September 1,...more

US Commodity Futures Trading Commission Extends No-Action Relief

by Shearman & Sterling LLP on

The CFTC extended the relief granted under No-Action Letters 15-62 and 15-63 until December 31, 2017. The extended no-action relief in CFTC Letter No. 16-80 exempts inter-affiliate swaps from the trade execution requirement...more

Orrick's Financial Industry Week in Review

Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more

CFTC Guidance on FCM and DCO Investments in Money Market Funds

by Dechert LLP on

Divisions of the U.S. Commodity Futures Trading Commission (CFTC) on August 8, 2016 issued letters restricting futures commission merchants (FCMs) and derivatives clearing organizations (DCOs) from investing in money market...more

CFTC Issues No-Action Letter to Swap Dealers to Extend Collateral Rule Deadline due to Limitations with Custodial Accounts

On September 1, 2016, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Swap Dealer and Intermediary Oversight announced that it “issued a time-limited, no-action letter stating that it will not recommend...more

CFTC Proposed Registration Relief for Non-U.S. Futures Commission Merchants, Commodity Pool Operators, Commodity Trading Advisors...

On July 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) proposed amendments to its rules (“Proposed Rules”) that loosen the conditions for exemption from registration as a futures commission merchant (“FCM”),...more

No-Action Letter Issued Regarding the OCR Final Rule

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the ownership and control final rule (the “OCR Final Rule”). The OCR Final Rule requires...more

US Commodity Futures Trading Commission Staff Provides Relief in Connection with Swap Trade Confirmations

by Shearman & Sterling LLP on

The Commodity Futures Trading Commission’s Division of Market Oversight issued a no-action letter extending the time period for relief from the requirement in CFTC Regulation 37.6 that a SEF obtain documents incorporated by...more

CFTC Extends No Action Relief for SEFs With Respect to Certain Uncleared Swaps Transactions

The Commodity Futures Trading Commission’s Division of Market Oversight has extended previously granted relief for Swap Execution Facilities (SEFs) with respect to requirements for certain transactions in uncleared swaps....more

CFTC Staff Provides Relief in Connection with Swap Trade Confirmations

On March 14, the U.S. Commodity Futures Trading Commission’s Division of Market Oversight published a time-limited no-action letter that changed the deadline “for relief in connection with swap trade confirmation...more

The Financial Report - Volume 5, No. 5 - March 2016 (Global)

by DLA Piper on

The buzz phrase of the moment in the financial services industry is robo adviser. On Monday, February 29, The Wall Street Journal published a Journal Report in the Personal Finance Section of that day’s newspaper. The...more

CFTC Extends Trade Option Reporting Deadline to April 1, 2016

by Latham & Watkins LLP on

The CFTC provides the market additional time to submit Form TO while considering further amendments to trade option reporting rules. On February 18, 2016, the US Commodity Futures Trading Commission's (the CFTC) Division...more

Financial Services & Products Advisory: CFTC Provides Swap Clearing Relief for Smaller Bank Holding Companies and Savings and Loan...

by Alston & Bird on

On January 8, 2016, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Clearing and Risk (DCR) issued a no-action letter (CFTC Letter 16-01) providing relief from the clearing requirement for some swaps...more

U.S. Commodity Futures Trading Commission Divisions Issue Time-Limited No-Action Letter Extending Relief from Certain...

On December 8, 2015, the U.S. Commodity Futures Trading Commission’s (the “CFTC”) Division of Swap Dealer and Intermediary Oversight and Division of Market Oversight issued a time-limited no-action letter extending the relief...more

U.S. Swap Dealers and Non-U.S. Major Swap Participants Under SDR Reporting Rules

On November 9, the U.S. Commodity Futures Trading Commission’s (the “CFTC“) Division of Market Oversight issued a time-limited no-action letter extending the relief provided in CFTC Letter No. 14-141. The relief applies to...more

No-Action Relief Granted to Foreign Branch of US Swap Dealer for Transaction-Level Requirements

In a recently released no-action letter, the Commodity Futures Trading Commission indicated it would not seek enforcement action against a US swap dealer and its counterparties where a foreign branch of the US swap dealer...more

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