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Reporting Requirements Commodities Futures Trading Commission

Mitratech Holdings, Inc

DOJ Unveils Whistleblower Rewards Program: What Every Business Needs to Know

The Department of Justice has launched the Corporate Whistleblower Awards Pilot Program to fight corporate crime. See how it impacts your organization. The U.S. The Department of Justice (DOJ) has just rolled out the...more

Orrick, Herrington & Sutcliffe LLP

CFTC orders bank to pay $5M for swap reporting violations

On August 26, the CFTC issued an order against a bank for allegedly failing to correctly report millions of swap transactions to a registered swap data repository, in violation of a prior CFTC order, and for failing to...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Cadwalader, Wickersham & Taft LLP

CFTC’s Recent Revisions to Reporting Rules for Futures, Options and Swaps

On April 30, 2024 the Commodity Futures Trading Commission (“CFTC” or the “Commission”) finalized amendments to its rules governing reporting requirements for large trader futures and options positions, the latest in a series...more

Carlton Fields

SEC and CFTC Amend Form PF … Again: Private Fund Advisers Should “Kick the Tires” Before Next Race to File

Carlton Fields on

In February 2024, the SEC and the Commodity Futures Trading Commission (CFTC) adopted major amendments to Form PF to provide greater transparency into the operations and strategies of private funds, and to assist the...more

Katten Muchin Rosenman LLP

The CFTC Adopts Amendments to Capital and Financial Reporting Requirements for Swap Dealers Largely Based on Prior Relief

After adopting final rules in 2020, the Commodity Futures Trading Commission (CFTC) adopted amendments to the capital and financial reporting requirements for Swap Dealers (SDs), which were largely based on prior no-action...more

Jones Day

Delegation Dilemma: CFTC Rule Allows Staff to Circumvent Notice and Comment Rulemaking

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The Commodity Futures Trading Commission ("CFTC") published a final rule on April 30, 2024, altering how covered entities fulfill their large trader reporting obligations ("the LTR Rule") and granting CFTC staff significant...more

Davis Wright Tremaine LLP

CFTC Finalizes Two Sets of Reporting Requirements

Updated: reporting requirements for swap dealers, swap participants, and large traders in the futures and options market On April 30, 2024, in two separate releases, the Commodity Futures Trading Commission ("CFTC")...more

BCLP

CFTC’s Updated Large Trader Report Rule Leaves Important Questions Unanswered

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Last week, the CFTC updated its large trader position reporting rules for futures and options. First proposed in June 2023, this much-needed change modernizes a rule that had gone largely unchanged since the 1980s....more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Enforcement Director Addresses Self-Reporting Benefits

On April 11, 2024, Ian McGinley, the director of enforcement at the Commodity Futures Trading Commission (CFTC) addressed the New York City Bar Association Futures and Derivatives Committee to present the benefits of...more

BCLP

CFTC’s Annual Enforcement Results: Another Blockbuster Year

BCLP on

The Commodity Futures Trading Commission ("CFTC") recently released its enforcement results for Fiscal Year 2023 ("FY 2023"), which ran from October 1, 2022, through September 30, 2023. ...more

Dechert LLP

SEC Adopts Third Set of Amendments to Form PF

Dechert LLP on

The latest round of revisions to Form PF made a stealthy arrival, with the SEC announcing in mid-February that it adopted the updates without an in-person vote. As the third set of amendments to Form PF in the past 12...more

American Conference Institute (ACI)

U.K. Parliament Giving Whistleblower Protections a Fresh Review

Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more

A&O Shearman

Announcement of new DOJ Whistleblower Policy

A&O Shearman on

On March 7, 2024, Deputy Attorney General Lisa Monaco announced a new 90-day pilot program at the Department of Justice (DOJ) to incentivize whistleblowers. The program is inspired by and generally follows similar programs...more

K&L Gates LLP

SEC and CFTC Adopt Amendments to Form PF for Increased Disclosure

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Brief Overview - On 8 February 2024, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF (the Amendments), the confidential reporting form...more

Morgan Lewis

SEC and CFTC Adopt Amendments to Form PF

Morgan Lewis on

On February 8, the US Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC and, together with the SEC, the Commissions) voted to adopt amendments to Form PF1 that will impact the...more

WilmerHale

CFTC Year in Review: 23 Takeaways From 2023 and Predictions for 2024

WilmerHale on

At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more

Katten Muchin Rosenman LLP

Third Time's a Charm? SEC & CFTC Finalize Amendments to Form PF

On February 8, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) jointly adopted amendments to Form PF, the confidential reporting form for certain registered investment advisers to...more

Morgan Lewis - Power & Pipes

CFTC 2023 Enforcement Report Shows Uptick in Enforcement Actions

The Commodity Futures Trading Commission (CFTC or Commission) released its enforcement results for fiscal year 2023 on November 7, 2023. The CFTC’s Division of Enforcement filed 96 enforcement actions in 2023 charging a range...more

Paul Hastings LLP

Daily Financial Regulation Update -- Friday, November 17, 2023

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November 16, 2023- The Financial Crimes Enforcement Network (FinCEN) has updated its Beneficial Ownership Information FAQs to include new questions about the reporting process, reporting companies, beneficial owners,...more

Kohn, Kohn & Colapinto LLP

SEC, CFTC Pass $2 Billion Award Milestone but Reforms are Still Needed

Combined, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have awarded more than $2 billion to whistleblowers. The agencies’ whistleblower programs, which were created...more

Cadwalader, Wickersham & Taft LLP

CFTC Extends OCR Final Rule Relief

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

Proskauer Rose LLP

Taskforce on Nature-Related Financial Disclosures – New and Updated Nature Reporting Recommendations Published

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The NY Climate Week conference took place during the week of 18 September 2023, bringing together international leaders from business and governments. During the conference the Taskforce on Nature-related Financial...more

K&L Gates LLP

The SEC Significantly Expands the Scope of Form PF Reporting

K&L Gates LLP on

Introduction and Summary - On 3 May 2023, the Securities and Exchange Commission (SEC) approved amendments to Form PF (the Amendments), the confidential reporting form required to be filed by certain SEC-registered private...more

Goodwin

New Form PF Current and Quarterly Event Reporting and Expanded Large Private Equity Fund Adviser Reporting Adopted By SEC

Goodwin on

On May 3, 2023, the Securities and Exchange Commission (the SEC) adopted important amendments to Form PF, the systemic risk reporting form for private fund advisers registered with the SEC, that would require (i) new...more

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