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On October 12, the Securities and Exchange Commission (SEC) voted to adopt new electronic recordkeeping requirements for broker-dealers, security-based swap dealers (SBSDs), and major security-based swap participants (MSBSPs)...more
INTRODUCTION - The Commodity Futures Trading Commission (CFTC or Commission) recently voted 3–2 to approve a final rule (Final Rule) on the cross-border application of certain swap provisions under the Commodity Exchange Act...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), signed into law on July 21, 2010, was the largest overhaul of the U.S. derivatives market in history. While there are still a few parts of Dodd-Frank...more
On March 16, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) approved a final rule that eliminates the reporting and recordkeeping requirements in current CFTC regulations for trade option counterparties that are...more
On May 2, 2014, the Securities and Exchange Commission (SEC)published in the Federal Register proposed regulations1 that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street...more
The SEC issued a release proposing recordkeeping, reporting, and notification requirements for security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”). Although described as seeking to...more
On April 17, the Securities and Exchange Commission proposed several new rules relating to security-based swaps. The rules deal with “recordkeeping, reporting, and notification requirements applicable to security-based swap...more
The SEC has published proposed recordkeeping, reporting and capital deficiency notification requirements that would apply to security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”) as well...more
Following up on its January 21, 2014, formation of an interdivisional staff working group (Working Group) to review its swap data reporting and other provisions of Part 45 of its regulations, on March 19, 2014, the Commodity...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
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
The CFTC has provided time-limited no-action relief for swap dealers, or SDs, and major swap participants, or MSPs, concerning certain recordkeeping obligations under Part 23 of the CFTC’s regulations. ...more
TABLE OF CONTENTS I. Who Does the Dodd-Frank Act Impact? ...1 A. Major Swap Participants...1 1. Category 1: Substantial Position in Swap Categories ...1 2. Category 2: Substantial Counterparty Exposure...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