News & Analysis as of

Final Rules Swaps Compliance

Katten Muchin Rosenman LLP

The CFTC Codifies the Letter 19-17 Compliance Processes Around Separately Margined Accounts

In 2014, the Joint Audit Committee issued a Regulatory Alert insisting that futures commission merchant (FCM) clearing members treat separate accounts of the same beneficial owner as a single account for purposes of US...more

Davis Wright Tremaine LLP

Swaps Enforcement Update: Business Conduct Standards for Swap Dealers and Major Swap Participants

While the initial swap dealer enforcement actions brought by the Commodity Futures Trading Commission (CFTC) focused on swap data reporting failures, recent enforcement efforts have focused on compliance with business conduct...more

Orrick - Finance 20/20

CFTC’s Division of Market Oversight Provides Additional Time to Comply with Electronic Reporting Requirements in the OCR Final...

Orrick - Finance 20/20 on

On September 28, the U.S. Commodity Futures Trading Commission’s (the “Commission”) Division of Market Oversight issued a no-action letter that provides reporting parties additional time to comply with certain reporting...more

Morrison & Foerster LLP

The SEC’s Registration Rules for Security-Based Swap Dealers

Early this month the U.S. Securities and Exchange Commission (“SEC”) released final rules (the “Registration Rules”) for the registration of security-based swap dealers (“SBSDs”). The Registration Rules, released more than...more

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