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 October 28, 2019, the SEC's Division of Trading and Markets granted no-action relief for a limited period of time to Paxos Trust Company, LLC from registration as a clearing agency under Section 17A(b)(1) of the Securities...more
CME and LCH Amend Rulebooks on Variation Margin - Market participants historically have characterized cleared derivatives as being "collateralized-to-market", treating variation margin transfers as daily collateral...more
The SEC recently published myriad questions about the listing, trading, and marketing (especially to retail investors) of "new, novel, or complex" exchange-traded products (ETPs). Such ETPs include exchange-traded funds...more
On August 13, 2015, CFTC Division of Swap Dealer and Intermediary Oversight, Clearing and Risk, and Market Oversight extended a time-limited no-action relief to swap dealers registered with the CFTC that are established under...more
The SEC granted no-action relief to Citizen VC, Inc. which appears to state, although subject to facts and circumstances, a pre-existing relation can be formed with a person that first contacts a seller of securities over the...more