The Situation: The Securities and Exchange Commission ("SEC") has reopened the comment period for its proposed rule requiring public disclosure of security-based swap ("SBS") positions that exceed certain thresholds....more
European investment managers of non-UCITs funds will have to be authorised as an alternative investment fund manager (known as an “AIFM” under AIFMD) under the Alternative Investment Fund Managers Directive (“AIFMD”) from 22...more
The CFTC announced that registered entities and swap counterparties subject to the CFTC’s jurisdiction may now comply with the CFTC’s swap data recordkeeping and reporting requirements with respect to Legal Entity Identifiers...more
On October 30, the Commodity Futures Trading Commission’s chief information officer announced that registered entities and swap counterparties subject to CFTC swap data recordkeeping and reporting requirements concerning...more
On June 10, the CFTC issued an amended order that revises an order issued on July 23, 2012, expanding the list of approved providers of Legal Entity Identifiers (LEIs) that can be used by registered entities and swap...more
In This Issue: OCC Issues Final Rule on Lending Limits; CFTC Temporary No-Action Relief for Transition to SEF Rule; FHFA Report to Congress; CFTC Temporary No-Action Relief for Small Bank Board Approval Requirements: CFTC...more
In this issue: - CFTC Expands List of Acceptable Legal Entity Identifiers - CFTC Delays Effective Date for Clearing Exemption for Swaps Between Affiliates - “Sophisticated Plaintiff” Found to Be Adequate...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
Some of the key changes to the swaps markets contemplated by the Dodd-Frank Act are starting to take effect. Some key upcoming deadlines affecting private investment funds are highlighted below. ...more
Every swap end user (i.e., any party to an outstanding derivative contract who is not a swap dealer or major swap participant) should be aware that April 10, 2013 is the deadline for obtaining a “CFTC Interim Compliant...more
In this issue: - SEC Seeks Information to Assess Standards of Conduct and Other Obligations of Broker-Dealers and Investment Advisers - Frequently Asked Questions About Legal Entity Identifiers - CFTC...more