After 15 years without significant revisions, the Alabama Department of Environmental Management (ADEM) is proposing an overhaul of its recycling rules. The proposed regulations, which ADEM released for public notice and...more
Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more
On April 28, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule targeting national security controlled exports and reexports to China, Russia, and...more
On April 19, 2018, the Canadian Securities Administrators (CSA) took a major step toward adopting a comprehensive regime for the regulation of those in the business of trading derivatives or advising on derivatives. The CSA...more
On May 12, 2016, securities regulators in Ontario, Quebec and Manitoba announced changes to existing derivatives trade reporting requirements that will be of interest to both derivatives dealers and “end-users” of...more
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
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
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
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
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
Trade reporting obligations take effect in Ontario, Quebec and Manitoba (Applicable Provinces) on June 30, 2015 and will require over-the-counter (OTC) derivatives transactions between “End-Users” to be reported if either or...more
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
The first half of 2014 will bring changes to the end user reporting requirements for trade options and swaps—namely, (1) the commencement of the annual Form TO reporting requirement for unreported trade options and (2) a...more
End users of swaps should be aware of three impending deadlines for complying with new Commodity Futures Trading Commission (CFTC) regulations....more
On the brink of the compliance date for arguably one of the most burdensome requirements that end-users face under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Commodity Futures Trading...more
Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more
In this issue: - SEC and CFTC Adopt Joint Rules to Help Protect Investors from Identity Theft - CME Block Trade Advisories Clarify Nonpublic Information Restrictions - CFTC Staff Issues No-Action Letters ...more
On April 9, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight, responding to requests from multiple interested parties, issued a no-action letter (the No-Action Letter) extending the April...more
The CFTC has issued a no-action letter that effectively extends the dates for swap counterparties who are not swap dealers (SDs) or major swap participants (MSPs) to come into compliance with the agency’s reporting rules...more
The CFTC Division of Market Oversight has issued an advisory to remind market participants of the swap reporting requirements that are now, or soon to be, in effect. End users must be in compliance with the reporting rules...more
The International Energy Credit Association (“IECA”) has released a standardized agreement titled the “Dodd-Frank Act Representations and Reporting Amending Agreement” to facilitate end user compliance with the CFTC’s swap...more