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Reporting Requirements Swaps

Proskauer - Regulatory & Compliance

CFTC Clarifies that FX Window Forwards are Not “Swaps”

On April 9, 2025, the Markets Participants Division and the Division of Market Oversight (collectively, the “Divisions”) of the Commodity Futures Trading Commission (the “CFTC”) published a Staff Letter (the “Staff Letter”)...more

A&O Shearman

UK Financial Conduct Authority policy statement on reforming commodity derivatives regulatory framework

A&O Shearman on

The Financial Conduct Authority (FCA) has published a policy statement (PS25/1) on reforming the commodity derivatives regulatory framework. The policy statement sets out the FCA's response to feedback on its consultation...more

BCLP

2024 CFTC Enforcement: Agency Celebrates Record Monetary Relief

BCLP on

On December 4, 2024, the Commodity Futures Trading Commission (“CFTC”) released its enforcement results for Fiscal Year 2024 (“FY 2024”), showcasing record awards of monetary relief totaling more than $17.2 billion....more

Moore & Van Allen PLLC

THE DESK: MVA’s Swaps & Derivatives Newsletter

Moore & Van Allen PLLC on

Our goal is simple, to provide you key updates and insights that you can quickly digest and easily share with your peers, boss, or anyone else that shares a passion for swaps and derivatives news. We know you have to move...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

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

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

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

Stikeman Elliott LLP

CSA Publish Derivatives Data Reporting Transition Guidance

Stikeman Elliott LLP on

Amendments to swap data reporting rules are expected to be implemented by the Commodity Futures Trading Commission (CFTC) in December 2022. The Canadian Securities Administrators (CSA) have issued guidance to market...more

Cadwalader, Wickersham & Taft LLP

CFTC Finalizes Rule Regarding LIBOR Transition Clearing Requirement Determination for Certain Interest Rate Swaps

On August 12, the Commodity Futures Trading Commission (“CFTC”) issued a final rule amending its Regulation 50.4(a) clearing requirements for swaps. The latest in a series of rulemaking that is supportive of the...more

Cadwalader, Wickersham & Taft LLP

CFTC’s Swap Reporting Advisory

Accurate and timely reporting of swap data is the cornerstone of swap regulation. The CFTC had promulgated its swap reporting rules in 2012, and were after 2012 among the first rules implementing the Dodd-Frank Act to...more

Morgan Lewis

National Futures Association Proposes New Reporting Requirements for Commodity Pool Operators

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The National Futures Association (NFA) has proposed a new rule that would require registered commodity pool operators (CPOs) that are members of the NFA (CPO Members) to report to the NFA by 5:00 pm Central Time the next...more

Morgan Lewis

CFTC Amends Real-Time Swap Public Reporting Requirements

Morgan Lewis on

The Commodity Futures Trading Commission (CFTC) has unanimously approved amendments to the real-time swap reporting rules in Part 43 of the CFTC’s regulations by, among other things, clarifying the applicability of the rules...more

Katten Muchin Rosenman LLP

Time for a Change: The CFTC Adopts Extensive Amendments to Swap Reporting Regulations to Improve Data Quality

Eight years after the Commodity Futures Trading Commission (CFTC or Commission) established a comprehensive swap data reporting and public dissemination regulatory regime, on September 17, the Commission adopted extensive...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Amends Swap Data Reporting Rules, Creates Registration Framework for Non-US Clearing Organizations

On September 17, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved final rules amending the agency’s swap data reporting and derivatives clearing organization (DCO) registration requirements. The...more

Orrick - Finance 20/20

CFTC Approves Final Swap Dealer Capital Rule

Orrick - Finance 20/20 on

On July 22, the Commodity Futures Trading Commission (CFTC) approved a final rule regarding new capital and financial reporting requirements for swap dealers and major swap participants that are not subject to supervision by...more

Stoel Rives - Renewable + Law

CFTC Proposed Rule Benefits Certain Financially-Settled Offtake Arrangements

On February 20, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved a proposed rule that would revise certain reporting requirements for financially-settled offtake contracts that qualify as “swaps”...more

WilmerHale

The SEC's Security-Based Swap Recordkeeping and Reporting Rules

WilmerHale on

On September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major...more

Vedder Price

SEC Issues New Rules for Security-Based Swaps

Vedder Price on

On December 18, 2019, the SEC adopted certain rule amendments to enhance the framework for regulating cross-border security-based swaps. Through this effort, the SEC established a broad security-based swap regulatory regime...more

Orrick - Finance 20/20

SEC Adopts New Rules and Amendments Under Title VII of Dodd-Frank

Orrick - Finance 20/20 on

On September 19, the SEC adopted new rules and amendments under Title VII of the Dodd-Frank Act establishing recordkeeping and reporting requirements for security-based swap dealers and major security-based swap participants,...more

WilmerHale

CFTC Proposes Additional Swap Data Reporting Requirements

WilmerHale on

The Commodity Futures Trading Commission (CFTC) is proposing a significant, new reporting burden on swaps reporting parties and on swaps data repositories (SDRs). The proposal would impose new requirements on SDRs to verify...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes Sweeping Swap Reporting Amendments Aimed at Improving Data Accuracy and Completeness

On April 25, 2019, the Commodity Futures Trading Commission (CFTC or Commission) published for public comment proposed amendments to the rules governing swap data repositories (SDRs) and reporting obligations of swap market...more

Opportune LLP

Derivative & Dodd-Frank Considerations for Wind Farm Owners

Opportune LLP on

Wind farm owners and project sponsors have increasingly turned to corporate power purchase agreements (PPAs) and other hedging alternatives to secure predictable cash flows. Depending on the structure of these agreements,...more

K&L Gates LLP

CFTC Proposes to Codify Relief for CPOs and CTAs

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Introduction - The U.S. Commodity Futures Trading Commission (“CFTC” or “Commission”) is proposing amendments to its regulations governing commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) to codify...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

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