On September 22, 2023, the Commodity Futures Trading Commission’s (the “CFTC” or the “Commission") Division of Market Oversight extended its no-action position regarding certain large trader reporting (“LTR”) obligations for...more
Key Points - Until August 12, 2025, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account...more
REGULATORY UPDATES - SEC - Leadership Changes On April 14, 2021, the U.S. Senate voted to approve President Biden’s nomination of Gary Gensler as Chairman of the Securities and Exchange Commission (the “SEC”) through June...more
U.S. Developments - Federal and State Regulatory Developments - U.S. Department of Homeland Security Issues Challenge for Development of Trusted User Interface for Digital Wallets - The U.S. Department of Homeland Security...more
Many Commodity Futures Trading Commission registrants and other market participants are responding to the coronavirus (COVID-19) pandemic by implementing business continuity plans that move personnel from their “normal...more
On March 17, 2020, in response to the COVID-19 (coronavirus) pandemic, the Commodity Futures Trading Commission (CFTC) Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) issued...more
In light of the growing impact from the COVID-19 (coronavirus) pandemic, the Commodity Futures Trading Commission’s (CFTC) Divisions of Swap Dealer and Intermediary Oversight (DSIO) and Market Oversight (DMO) issued eight...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
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
While not unlimited, the relief is welcome for counterparties seeking to transition to risk-free rates for legacy swaps. The US Commodity Futures Trading Commission (CFTC) has issued no-action relief to help market...more
Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more
On November 25, 2019, the Commodity Futures Trading Commission (CFTC) approved final rule amendments intended to simplify certain existing CFTC rules, codify certain previously granted no-action relief, and better coordinate...more
On November 18, 2019, the Chairman of the Commodities and Futures Trading Commission (“CFTC”), Heath Tarbert, sat for an interview on digital assets and did something we have never seen before. He declared the winner of the...more
Introduction - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for floor traders to “encourage new liquidity providers to trade cleared swaps on registered venues without...more
In response to a request from the International Swaps and Derivatives Association, the Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight issued no-action relief that will permit swap...more
The Commodity Futures Trading Commission ("CFTC") extends no-action and exemptive relief from the European Union to the United Kingdom. On April 5, 2019, the CFTC's Divisions of Clearing and Risk, Market Oversight and Swap...more
Relief issued by the US Commodity Futures Trading Commission resolves any doubts that UK firms, as well as their swap counterparties and affiliates, may have had about whether no-action relief would continue to apply to UK...more
BROKER-DEALER - Nasdaq Proposes Rule Change to SEC to Assume Operational Responsibility for Certain Investigation and Enforcement Functions Currently Performed by FINRA - On April 3, the Securities and Exchange...more
On October 18, 2018, the Commodity Futures Trading Commission (CFTC) published a proposal in the Federal Register (Proposed Rule) to amend several key compliance and registration regulations governing commodity pool operators...more
DERIVATIVES - SEC Issues Statement on Swap Business Conduct Rules - On October 31, the Securities and Exchange Commission took an unusual additional step towards implementing its rules for security-based swaps (SBS) by...more
On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (“DSIO“) announced “conditional, time-limited no-action relief to a banking entity for not counting...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
FHFA Updates Progress on Fannie Mae and Freddie Mac Credit Risk Transfer Programs - On November 22, 2017, the Federal Housing Finance Agency ("FHFA") issued a status report on credit risk transfer transactions done in...more
On November 20, 2017, the Commodity Futures Trading Commission (“CFTC“) provided “no-action relief to swap execution facilities [] from the timing requirement within CFTC regulation 37.1501(f)(2), which requires a chief...more
The Commodity Futures Trading Commission Division of Market Oversight has issued no-action relief to Swap Execution Facilities and their chief compliance officers from certain timing requirements regarding annual compliance...more