The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more
On November 5, 2018, the Commodity Futures Trading Commission (CFTC) unanimously adopted a final rule to set a permanent $8 billion swap dealing activity threshold for purposes of the swap dealer de minimis exemption (Final...more
Pursuant to regulations promulgated under the Dodd-Frank Act, entities that make a market in swaps, hold themselves out as dealers in swaps or regularly enter into swaps for their own accounts are required to register as swap...more
At the Commodity Futures Trading Commission's open meeting on June 4, 2018, the CFTC voted to propose rules that would permanently maintain the swap dealer de minimis registration threshold at $8 billion. The Commission voted...more
BROKER-DEALER - FINRA Proposes Rule Change Regarding ATS Reporting of Transactions to TRACE - The Financial Industry Regulatory Authority recently filed a proposed rule change with the Securities and Exchange Commission...more
Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more
CFTC Delays Reduction in Swap Dealer De Minimis Exception Threshold - On October 13, 2016, the Commodity Futures Trading Commission approved an Order delaying for one year the reduction of the threshold for determining...more
As has been rumored in recent weeks, the CFTC has adopted an order establishing December 31, 2018 as the swap dealer registration de minimis threshold phase-in termination date. With this approval, the de minimis threshold...more
Under current CFTC rules, market participants who exceed $8 billion in gross notional swap dealing activity over a twelve-month period are required to register with the CFTC as swap dealers during the phase-in period...more
On November 18, the staff of the Commodity Futures Trading Commission (CFTC) issued a much anticipated report on the de minimis exception from the “swap dealer” definition, the Swap Dealer De Minimis Exception Preliminary...more
On November 18, staff from the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and Office of the Chief Economist issued a preliminary report regarding the swap dealer de minimis...more
CFTC staff issued a preliminary report regarding the swap dealer de minimis exception. Under CFTC rules, market participants who exceed $8 billion in gross notional swap dealing activity over a twelve-month period are...more
The Commodity Futures Trading Commission has proposed to amend the “special entity” de minimis exception from swap dealer designation to exclude certain swaps with public utility providers. The proposed regulations are...more