Confirmations: NFA and CME’s Financial Match.com
Confirmations: Plugging Into Electronic Confirmations
CFTC Proposal Poses “Monumental” Challenge to FCMs
Daily Reports: Tell Us Where The Money Is
Customer Protection Fund: Slip it to SIPC
Customer Segregation: Keep It Separate
Cole-Frieman & Mallon partner/co-founder Bart Mallon Discusses CFTC Regulation 4.5, the Volcker Rule & Other Compliance Issues
Derivatives Attorney Jim Falvey Discusses the MF Global bankruptcy, the Volcker Rule & Compliance Issues Related to Dodd-Frank
Part 17 of the CFTC’s regulations require futures commission merchants, clearing members of registered derivatives clearing organizations, and foreign brokers holding omnibus accounts with such FCM clearing members to submit...more
This post is the next installment in a multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”)....more
The previous post in this series discussed how different market participants hold different views of the relationship between an investment manager and its clients, particularly in the separate account context. That post...more
At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more
In Short - The Situation: In a December 13, 2023, Open Meeting, the Commodity Futures Trading Commission proposed amendments to the Commission's regulations concerning clearing member funds held by a derivatives clearing...more
On November 3, 2023, the Commodity Futures Trading Commission (“CFTC”) proposed to significantly amend the rules on investment of customer funds by futures commission merchants (“FCMs”) and derivatives clearing organizations...more
Once, many years ago, the Joint Audit Committee released a Regulatory Alert (RA 14-03) addressed to futures commission merchants that are clearing members of derivatives clearing organizations registered with the CFTC, which...more
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
CME Group Proposes New Clearing Member Category to Help Customers Avoid Pro Rata Distribution Risk in Case of FCM Insolvency: CME Group filed proposed rule changes with the Commodity Futures Trading Commission that would...more
On February 1, the Commodity Futures Trading Commission issued an order granting Eurex Clearing AG registration as a derivatives clearing organization (DCO) under the Commodity Exchange Act (CEA). The order will allow Eurex...more
The CFTC approved final rules requiring enhanced protections afforded customers and customer funds held by futures commission merchants (“FCMs”). The rules require FCMs to adopt and enforce a risk management program,...more
On October 30, 2013, in a 3-1 vote, the Commodity Futures Trading Commission (CFTC or the Commission) approved final rules that significantly strengthen the protections afforded to customers of futures commission merchants...more
The Commodity Futures Trading Commission (CFTC or Commission) recently adopted several rules to improve large trader reporting, facilitate segregation of customer swap margin and enhance customer protections for futures and...more
On June 19, the National Futures Association (NFA) issued a notice to its members regarding the implementation of the second phase of the segregated account balance reporting requirements under Section 4 of the NFA’s...more
On October 23, the CFTC proposed new regulations and amendments to existing regulations to enhance protections for customers and to strengthen safeguards for the holding of money, securities, and other property deposited by...more
In This Issue: - CFTC Proposes Rules For Future Commission Merchants and Derivative Clearing Organizations - CFTC Adjusts the Maximum Civil Monetary Penalties for Inflation - CFTC Announces Temporary...more
The Commodity Futures Trading Commission published proposed rules that are designed to increase protections for customers and customer funds held by futures commission merchants (FCMs) and derivatives clearing organizations...more
The Commodity Futures Trading Commission has announced that it will hold a public meeting to consider proposed rules that would enhance protections afforded customers and customer funds held by futures commission merchants...more
The Commodity Futures Trading Commission’s Division of Clearing and Risk (Division) has advised clearing member futures commission merchants (FCMs) and derivatives clearing organizations (DCOs) of the Division’s position...more
In This Issue: - CFTC Proposes Inter-Affiliate Clearing Exemption - CFTC Proposes Exemption For Certain Non-Financial Energy Derivative Transactions - CFTC Approves Conforming Rule on Registration of...more