The Global Foreign Exchange Committee has published an update on the ongoing work of its four priority working groups: (i) the cover and deal working group; (ii) the disclosures working group; (iii) the buy-side outreach...more
On June 29, 2018, the U.S. Commodity Futures Trading Commission (CFTC) and the U.S. Securities and Exchange Commission (SEC, and together the Commissions) announced that the Commissions approved a memorandum of understanding...more
Because of the implementation of new regulatory requirements relating to both variation and initial margin for swaps, swap documentation for many market participants is about to become much more complicated....more
The Bank for International Settlements published the Phase 1 materials for a global Code for the FX market. The Code is a set of principles providing common guidelines to promote the integrity and effectiveness of the global...more
To clarify our intended audience, in the Financial Entity Update we will address issues germane to entities that trade swaps but are neither dealers nor commercial end users. This includes a broad and diverse group of...more
On July 22, the European Commission answered the question on whether a rolling spot Foreign Exchange on margin takes the form of a derivative contract or a contract for difference to be considered a financial instrument under...more
In late June 2013, the Commodity and Futures Trading Commission (CFTC) issued a no-action letter extending the period for certain corporate end-users of foreign exchange (FX) derivative transactions to comply with the trading...more
Implementation of the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) affecting users of swaps and derivatives has been moving forward. Numerous rules of the Commodity Futures...more
In This Issue: Regulatory Updates - FSOC, FSB Turn Up Heat on SEC on Money Market Fund Reforms; SEC Staff: Beware of BDC Joint Transactions; SEC Reports 3,000 Whistles Blown in FYI 2012; Over 1500 Private Fund Advisers...more
The Commodity Futures Trading Commission (CFTC) released a series of staff letters relating to various issues arising under rules implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act, including chief...more
The Commodity Exchange Act, or CEA, as amended by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, authorizes the Secretary of the Treasury to issue a written determination that foreign exchange...more
On October 12, 2012, the Commodity Futures Trading Commission’s (CFTC) and Securities and Exchange Commission’s (SEC) final rules to further define the term “swap” (among other terms) became effective. The effective date of...more
Introduction - On July 18, 2012, the Securities and Exchange Commission (the “SEC”) and the Commodity Futures Trading Commission (the “CFTC” and, together with the SEC, the “Commissions”) jointly published several final rules...more
On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) was enacted. Title VII of Dodd-Frank amends the Commodity Exchange Act (CEA) and other federal securities laws to provide a...more