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, 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
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
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 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
In the almost six years since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the US Commodity Futures Trading Commission (CFTC) has, in large part, finalized its rulemakings...more
The Commodity Futures Trading Commission is seeking additional comments on its proposed regulations relating to position limits for physical commodity derivatives. The CFTC will accept comments on its proposals regarding...more
The United States District Court for the District of Columbia granted summary judgment for plaintiffs International Swaps and Derivatives Association (ISDA) and Securities Industry and Financial Markets Association (SIFMA),...more
In This Issue: Excerpt from Year-End Tax Planning Steps for Private Equity The last time the Bush tax cuts were set to expire at the end of 2010, we saw numerous clients scrambling to execute end-of-the-year...more
On September 28, 2012, in the case of International Swaps and Derivatives Association v. U.S. Commodity Futures Trading Commission, the District Court for the District of Columbia (the "Court") ruled that the Commodity...more
On September 28, 2012, Judge Robert Wilkins of the U.S. District Court for the District of Columbia granted the summary judgment motion of the International Swaps and Derivatives Association and Securities Industry and...more
Last Friday, September 28th, the U.S. Federal District Court in Washington, D.C. (“Court”) struck down the commodity speculative position limit rulemaking that the U.S. Commodity Futures Trading Commission (“CFTC”) had...more
The CFTC’s final rule on position limits with respect to derivative contracts in 28 different physical commodities has been vacated and remanded back to the agency. Spot month limits under the rule had been set to go into...more
Discussion Topics •General Overview of the Dodd-Frank Act •Title VII of the Dodd Frank Act: Impact on OTC Derivatives and Energy Trading •Definitions and applicability •Mandatory clearing •Registration requirements ...more