On September 17, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved final rules amending the agency’s swap data reporting and derivatives clearing organization (DCO) registration requirements. The...more
Toward the end of 2018, the Commodity Futures Trading Commission (CFTC) proposed significant revisions to the framework governing swap trading through swap execution facilities (SEFs) and designated contract markets (DCMs)....more
The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), signed into law on July 21, 2010, was the largest overhaul of the U.S. derivatives market in history. While there are still a few parts of Dodd-Frank...more
Less than two weeks into the new congressional session, the U.S. House of Representatives passed by a vote of 239 to 182 the Commodity End-User Relief Act1 (the Bill or House Bill), marking the first step by the new...more
On June 9, the Commodity Futures Trading Commission (CFTC) released a notice of proposed rulemaking regarding an expansion of CFTC Regulation 50.4(a). If adopted, additional classes of interest rate swaps will become subject...more
On June 9, 2016, the Commodity Futures Trading Commission (CFTC) proposed to require additional interest rate swaps to be centrally cleared. Since December 2012, the CFTC has required four classes of interest rate swaps...more
On January 8, 2016, the Division of Clearing and Risk (“Division”) of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters providing relief from the mandatory clearing requirement for swaps under Section...more
On October 14, 2015, the Division of Market Oversight (“DMO”) for the U.S. Commodity Futures Trading Commission (“CFTC”) issued an additional extension of no-action relief for swaps executed as part of “package” transactions....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
The Dodd-Frank Wall Street Reform and Consumer Protection Act’s mandatory clearing requirement for interest rate swaps and certain credit default swaps has been in place for quite some time. However, the clearing requirement...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
The latest edition of Financial Services Europe and International Update from Dechert’s Financial Services Practice covers the most recent regulatory developments. In This Issue: - Part A – Regulation of Financial...more
On June 4, the CFTC issued a no-action letter providing relief from the clearing requirement for swaps entered into by eligible treasury affiliates....more
The Commodity Futures Trading Commission recently released two no-action letters (i) extending relief provided to futures commission merchants (FCMs) relating to risk-based limits for bunched orders and (ii) providing relief...more
On April 1, the Commodity Futures Trading Commission approved a final rule that permits certain affiliates to elect not to clear a swap. To qualify for the clearing exemption, the counterparties’ financial statements must be...more
On 8 March 2013, The International Swaps and Derivatives Association, Inc (“ISDA”) published the ISDA 2013 EMIR NFC Representation Protocol (the “Protocol”). Adherence to the Protocol provides parties to ISDA Master...more
The CFTC has issued a final rule to exempt swaps between certain affiliated entities within a corporate group from the clearing requirement under the Commodity Exchange Act, or CEA, and CFTC regulations. ...more
On March 18, the Commodity Futures Trading Commission’s Division of Clearing and Risk granted no-action relief relating to the clearing requirement for swaps resulting from multilateral portfolio compression exercises (as...more
The CFTC’s Division of Clearing and Risk has issued a no-action letter that provides relief from required clearing for a limited set of “stub swaps” that remain after the partial novation or partial termination of an original...more
In this issue: - NASDAQ Proposes Internal Audit Function Requirement for Listed Issuers - FINRA’s Frequently Asked Questions on Electronic Blue Sheet Submissions Updated Regarding Order Execution Time -...more
In This Issue: *Financial Industry Developments - CFTC Announces the Start of Mandatory Clearing - CFTC Reminds Market Participants of Swap Data Reporting Requirements - Rating Agency Developments ...more
On March 11, the CFTC announced that swap dealers, major swap participants, and private funds active in the swaps market are required to begin clearing certain index credit default swaps and interest rate swaps that they...more
Swap dealers, major swap participants and private funds active in the swaps market are required to begin clearing certain index credit default swaps, or CDS, and interest rate swaps that they entered into on or after March...more
New Commodity Futures Trading Commission (CFTC) swaps clearing rules will force non-financial entities to stop uncleared trading of certain interest-rate swaps (IRS) and index credit default swaps (index CDS) starting on...more