Jill Sommers Reflects on the CFTC, Dodd-Frank, and Her Future
Regulation 2013: Dodd-Frank Position Limits, CFTC Reuthorization, Regulatory Harmonization
The Commodity Futures Trading Commission, by a 3-2 vote on October 15, 2020, adopted amendments to Part 150 of the CFTC Regulations (Amendments). Part 150 currently imposes federal speculative position limits on nine futures...more
INTRODUCTION - The Commodity Futures Trading Commission (CFTC) recently voted 3–2, along party lines, to approve a final rule (Final Rule) regarding position limits for certain futures contracts and economically equivalent...more
On October 15, 2020, the Commodity Futures Trading Commission (CFTC) voted 3-2 to adopt new rules on speculative position limits (the Final Rule). The Final Rule will become effective 60 days after publication in the Federal...more
On October 15, the Commodity Futures Trading Commission adopted new rules on position limits. The new rules mark an important step forward in a decade-long journey to enact one of the remaining key provisions of Title VII of...more
After a decade of rulemaking efforts, the Commodity Futures Trading Commission is proposing revisions to its regulations concerning federal speculative position limits to conform to the Wall Street Transparency and...more
On January 30, 2020, the Commodity Futures Trading Commission (CFTC or Commission) voted 3-2 to issue a proposed rulemaking on speculative position limits (the Proposal). The Proposal would apply spot month-only federal...more
On 30 January 2020 the Commodity Futures Trading Commission (CFTC) approved on a 3-2 vote proposed rules addressing position limits on speculative derivatives (Position Limits Proposal). The Position Limits Proposal has a...more
Will the fourth time be the charm? This week, the Commodity Futures Trading Commission will try for the fourth time since 2011 to revise its speculative position limits rules. Details have not been made public, but Heath...more
Until August 12, 2022, 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 controller”...more
The European Securities and Markets Authority has published an Opinion (dated September 24, 2018) on position limits for U.K. Natural Gas Contracts, for the purposes of the position limit regime established by the revised...more
Implementation of MiFID - The FSMA issued on 18 July 2017 a communication (the “Communication”) on the preparation for the entry into force of the Directive 2014/65/EU on Markets in Financial Instruments (“MiFID II”). Such...more
The CFTC’s Division of Market Oversight issued a time-limited no-action letter stating that, from February 14, 2017 to August 14, 2017, it will not recommend an enforcement action for failure to file a notice when relying on...more
Retail Foreign Exchange Dealer Agrees With CFTC and NFA to Cease Doing Business for Concealing Relationship With Closely Tied Market Maker - Forex Capital Markets, LLC, a retail foreign exchange dealer, and two of its...more
SEC/CORPORATE - Acting SEC Chair Directs Staff to Reconsider Pay Ratio Disclosure Rule - On February 6, the acting Securities and Exchange Commission Chairman, Michael Piwowar, issued a statement soliciting public...more
On December 5, the Commodity Futures Trading Commission (CFTC) issued final regulations regarding the aggregation of positions and accounts to assess compliance with speculative position limits, as well as to add a potential...more
Key Points - - Unless an exemption from aggregation is available, all positions in accounts for which any person controls the trading or holds a 10 percent or greater ownership or equity interest must be aggregated...more
SEC/CORPORATE - Supreme Court Rules on Insider Trading Involving Family and Friends - In its first insider trading decision in nearly two decades, the US Supreme Court ruled unanimously to uphold an insider trading...more
Last week, the Commodity Futures Trading Commission proposed revised position limit rules and finalized requirements related to the aggregation of positions and accounts to assess compliance with speculative position limits...more
The CFTC issued for public comment a supplement to the CFTC’s December 2013 position limits proposal. The supplement would permit exchanges to recognize, subject to CFTC review, certain positions in commodity derivative...more
In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more
On May 26, the Commodity Futures Trading Commission (CFTC) proposed amendments to its previously proposed rules related to speculative position limits on 28 core referenced futures contracts (the "2016 Amendment"). If...more
BROKER-DEALER FINRA - Issues Guidance With Respect to Stop Orders and Volatile Market Conditions - On May 26, FINRA issued guidance encouraging firms to review their policies with respect to the use of stop orders...more
On May 26, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved a proposed supplement (“Supplemental Proposal”) to its December 2013 proposal to establish position limits on futures and economically...more
The Commodity Futures Trading Commission (CFTC or Commission) adopted a final rule effective March 21, 2016, that eliminates the reporting and recordkeeping requirements under the CFTC’s existing trade option exemption for...more
On March 16, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved amendments to the rules applicable to certain physically-settled options referred to as “trade options.” This final rule substantially...more