News & Analysis as of

DSIO

Orrick, Herrington & Sutcliffe LLP

The CFTC Issues Advisory Regarding an FCM's Risks of Accepting Virtual Currency into Segregation

Virtual currency presents risks to futures commission merchants (FCMs) when deposited by futures customers or cleared swaps customers to margin futures, options on futures, or cleared swap transactions, according to an...more

Latham & Watkins LLP

CFTC Adds Another Building Block to its Digital Asset Framework

Latham & Watkins LLP on

The CFTC issues stringent guidelines for FCMs seeking to custody digital assets in connection with physically delivered futures contracts or swaps. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap...more

Orrick - On the Chain

CFTC: Virtual Currency Creates Real Segregation Risks

Orrick - On the Chain on

Virtual currency presents risks to futures commission merchants (FCMs) when deposited by futures customers or cleared swaps customers to margin futures, options on futures, or cleared swap transactions, according to an...more

Orrick - Finance 20/20

CFTC Further Extends Certain No-Action Relief to Market Participants in Response to COVID-19

Orrick - Finance 20/20 on

On September 11, the Commodity Futures Trading Commission (CFTC) announced the Division of Swap Dealer Intermediary Oversight (DSIO) and the Division of Market Oversight (DMO) are further extending certain elements of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Updates LIBOR Transition Relief

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

White & Case LLP

COVID-19 Response: US financial services regulatory (Updated April 24, 2020)

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In response to the global COVID-19 crisis, US federal financial regulators are taking important actions that affect US and non-US financial institutions, other financial services providers, consumers, and the US and global...more

Dechert LLP

CFTC and NFA Issue Relief for Registered CPOs and CTAs in Response to Disruptions Caused by COVID-19 Coronavirus Pandemic

Dechert LLP on

The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue...more

Morgan Lewis

CFTC No-Action Relief for Registrant and Market Participant COVID-19 Response

Morgan Lewis on

Many Commodity Futures Trading Commission registrants and other market participants are responding to the coronavirus (COVID-19) pandemic by implementing business continuity plans that move personnel from their “normal...more

Skadden, Arps, Slate, Meagher & Flom LLP

COVID-19: CFTC Issues No-Action Relief for Market Participants

On March 17, 2020, in response to the COVID-19 (coronavirus) pandemic, the Commodity Futures Trading Commission (CFTC) Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) issued...more

WilmerHale

Coronavirus COVID 19 CFTC and NFA Issue Relief and Guidance

WilmerHale on

The Commodity Futures Trading Commission (CFTC or Commission) has issued a series of eight staff letters which will facilitate the functioning of the derivatives markets during the COVID-19 pandemic. These actions will assist...more

Stinson - Corporate & Securities Law Blog

CFTC Grants Work From Home Relief to Deal With COVID-19

The CFTC announced the Division of Swap Dealer and Intermediary Oversight (DSIO) has issued a number of no-action letters providing temporary, targeted relief to futures commission merchants, introducing brokers, swap...more

Latham & Watkins LLP

A CFTC Helping Hand: DSIO Offers to Review Digital Asset Products

Latham & Watkins LLP on

Product innovation (including in pooled investment vehicles) is encouraged, but innovation must be consistent with the law. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap Dealer and Intermediary...more

Perkins Coie

Statement of DSIO Director Joshua B. Sterling on Supporting Innovation in Digital Asset Products, including Pooled Investment...

Perkins Coie on

The CFTC DSIO Division Director issued a statement reminding the industry that pooled investment vehicles that trade futures, swaps, and other commodity interests that reference digital assets like Bitcoin and stablecoins are...more

Latham & Watkins LLP

CFTC Issues No-Action Relief for Derivatives Market IBOR Transition

Latham & Watkins LLP on

While not unlimited, the relief is welcome for counterparties seeking to transition to risk-free rates for legacy swaps. The US Commodity Futures Trading Commission (CFTC) has issued no-action relief to help market...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Illusory Promise or Real Change? Transition at CFTC Brings Hope for Dodd-Frank Act Revisions

Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more

Orrick - Finance 20/20

CFTC Issues Advisory Regarding Chief Compliance Officer Annual Report Requirements

Orrick - Finance 20/20 on

On December 4, the CFTC issued an advisory (Staff Advisory 19-24) providing further guidance on certain requirements applicable to swap dealers, futures commission merchants and major swap participants (collectively,...more

Morgan Lewis

DSIO Director Explains Thematic Commodity Pool Operator Swap Dealer Review Program

Morgan Lewis on

In late September, the director of the Division of Swap Dealer and Intermediary Oversight (DSIO) of the US Commodity Futures Trading Commission (CFTC), Joshua Sterling, announced a new examination program for commodity pool...more

Dechert LLP

New CFTC DSIO Director Outlines Components of Regulatory Program Applicable to Asset Managers; Addresses Extension of the CFTC...

Dechert LLP on

Director Joshua B. Sterling of the CFTC’s Division of Swap Dealer and Intermediary Oversight (DSIO or Division) delivered several speeches in September and early October 2019, setting forth certain guiding principles and the...more

Kramer Levin Naftalis & Frankel LLP

CFTC Divisions Release 2019 Enforcement Priorities

In a regulatory first, the Commodity Futures Trading Commission (CFTC) announced its 2019 examination priorities for registrants of the Division of Market Oversight (DMO), the Division of Swap Dealer and Intermediary...more

WilmerHale

CFTC Announces Examination Priorities for 2019

WilmerHale on

On February 12, 2019, the Commodity Futures Trading Commission (CFTC or Commission) published for the first time its examination priorities for the coming year. The release of the priorities will provide legal and compliance...more

A&O Shearman

CFTC Divisions Outline Examination Priorities for 2019

A&O Shearman on

On February 12, 2019, the Commodity Futures Trading Commission (CFTC) published the 2019 examination priorities for its Division of Market Oversight (DMO), Division of Swap Dealer & Intermediary Oversight (DSIO) and Division...more

Orrick - Finance 20/20

DSIO Issues Time-Limited, Conditional No-Action Relief for Excluding Certain Loan-Related Swaps from Counting toward the Swap...

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (“DSIO“) announced “conditional, time-limited no-action relief to a banking entity for not counting...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

CFTC Reduces Marketplace Barriers for Global Development Initiatives - On May 16, 2018, the Commodity Futures Trading Commission's ("CFTC") Division of Swap Dealer and Intermediary Oversight ("DSIO") granted relief to...more

Eversheds Sutherland (US) LLP

CFTC takes steps to increase regulatory oversight of virtual currency markets

On May 21, 2018, the Commodity Futures Trading Commission (CFTC) announced two actions intended to increase surveillance of virtual currency markets and enforcement of the Commodity Exchange Act in relation to these markets....more

Orrick - Finance 20/20

CFTC Reduces Marketplace Barriers for Global Development Initiatives

Orrick - Finance 20/20 on

On May 16, 2018, the Commodity Futures Trading Commission’s (“CFTC“) Division of Swap Dealer and Intermediary Oversight (“DSIO“) granted relief to non-U.S. counterparties who enter into swaps with International Financial...more

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