News & Analysis as of

FX Swaps

Dechert LLP

EMIR Alert: Margin Clarity Ahead

Dechert LLP on

Earlier this month, the ESAs published a final report on proposed updates to the existing EMIR margin rules (the “Margin RTS Updates”). Although not yet final, the absence of a public consultation and fast approaching...more

A&O Shearman

Global Foreign Exchange Committee Update and Survey on Adoption of the FX Global Code

A&O Shearman on

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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC and SEC Approve Revised Memorandum of Understanding on Information Sharing

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

Troutman Pepper Locke

Documentation for the New Swap Margin Rules and Thoughts for the Buy Side and End Users

Troutman Pepper Locke on

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

A&O Shearman

First Phase of Global FX Code Released

A&O Shearman on

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

McGuireWoods LLP

Financial Entity Update: The CFTC’s Proposed Margin Rules for Uncleared Swaps – Know Thyself

McGuireWoods LLP on

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

Dechert LLP

Fairer and More Effective Fixed-Income, Currency and Commodity Markets?

Dechert LLP on

At the annual Mansion House speech to the City on Wednesday, 10 June, Bank of England (BoE) Governor Mark Carney announced an end to “the age of irresponsibility”. Shortly before the Mansion House speeches began, the...more

Orrick - Finance 20/20

European Commission Updates MiFID Q&A Website

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

Wilson Sonsini Goodrich & Rosati

CFTC Extends Deadline to Comply with Certain Trading Documentation Requirements Under Dodd-Frank for Corporate End-Users of...

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

Foley & Lardner LLP

Imminent Dodd-Frank Compliance Issues for Users of Swaps and Derivatives

Foley & Lardner LLP on

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

Morrison & Foerster LLP

Investment Management Legal + Regulatory Update -- December 2012

Morrison & Foerster LLP on

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

Katten Muchin Rosenman LLP

CFTC Issues No-Action Letters

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

Stinson - Corporate & Securities Law Blog

Treasury Issues Foreign Currency Swap and Forward Exemption

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

Eversheds Sutherland (US) LLP

CFTC Affords Relief and Guidance in Light of Final Swap Definition’s Effective Date

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

K&L Gates LLP

Swap Definitions Rules Finalized by the SEC and the CFTC under Dodd-Frank

K&L Gates LLP on

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

Wilson Sonsini Goodrich & Rosati

Update: Dodd-Frank Rules Impact End-Users of Foreign Exchange Derivatives - Companies That Hedge Foreign Exchange Exposures Need...

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

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