Podcast: CFTC Issues LIBOR Transition Relief for Swaps
LEGAL ALERT: CFPB Issues Proposed Revisions to No-Action Letter Policy
Open for Business: SEFs Navigate the New Regulatory Environment
Derivatives market participants continue to process the implications of two significant interpretive letters issued by the Commodity Futures Trading Commission (CFTC) staff earlier this year. Letter 25-09 effectively...more
The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more
On December 17, 2019, three different divisions of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters intended to facilitate the swaps market’s transition away from interbank offered rates (each, an...more
On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more
CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps - On August 19, The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments to existing rules relating...more
On June 15, CFTC Division of Market Oversight published a letter extending the time-limited relief provided by previously issued no-action letter 14-90, expiring on June 30, 2015, to June 30, 2016. The relief applies to the...more
Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more
On May 19, the Commodity Futures Trading Commission issued two no-action letters granting relief to certain swaps trading platforms in Australia and participants executing swaps transactions on such platforms....more
In November 2012, the CFTC's Division of Swap Dealer and Intermediary Oversight issued a no-action letter stating that the Division would not recommend that the CFTC take enforcement action against a family office for failure...more
On June 25, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) extended to October 31 the relief previously granted in CFTC No-Action Letters Nos. 14-02 and 14-45....more
In this issue: - Delaware Fee-Shifting Legislation Delayed - SEC Orders Securities Exchanges and FINRA to Develop Tick Size Pilot Plan - CFTC Extends Relief to FCMs from Certain Commingling Requirements ...more
The Commodity Futures Trading Commission has proposed to amend the “special entity” de minimis exception from swap dealer designation to exclude certain swaps with public utility providers. The proposed regulations are...more
The Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight of the Commodity Futures Trading Commission have issued relief from certain recordkeeping obligations for persons that are not...more
The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) recently addressed for the first time the CFTC’s definition of a “swap” as it applies to a specific insurance...more
On May 12, 2014, the Division of Swap Dealer and Intermediary Oversight (Division) of the Commodity Futures Trading Commission (CFTC) released its long-awaited commodity pool operator (CPO) delegation no-action letter...more
On April 9, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight jointly issued CFTC No-Action Letter No. 14-46, which modifies the conditions...more
No-Action Letter Provides Relief to M&A Brokers - On January 31, in a significant no-action letter (Letter), the Staff of the Division of Trading and Markets provided assurances that it would not recommend enforcement...more
The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued two no-action letters granting relief to futures commission merchants (FCMs) from certain requirements of the...more
In this issue: - Delaware Court of Chancery Upholds Forum Selection Provisions in Bylaws - CFTC Issues No-Action Letters - Portfolio Reconciliation and Swap Trading Relationship Documentation Requirements...more
Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more
In this issue: - SEC and CFTC Adopt Joint Rules to Help Protect Investors from Identity Theft - CME Block Trade Advisories Clarify Nonpublic Information Restrictions - CFTC Staff Issues No-Action Letters ...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
The Commodity Futures Trading Commission staff recently released a series of letters relating to a variety of regulatory issues, including registration relief for certain entities and recordkeeping requirements for certain...more
In this issue: - SEC Advisory Committee on Small and Emerging Companies Makes Recommendations - SEC Provides Guidance Regarding Social Media and Regulation Fair Disclosure (Regulation FD) - SEC Amends...more
Commodity Futures Trading Commission Staff have released several no-action letters relating to various requirements associated with swap trading, including swap dealer (SD) reporting requirements, SD chief compliance officer...more