News & Analysis as of

Required Documentation Swap Dealers

Guide to U.S. Variation Margin Documentation for Financial End Users

by Holland & Knight LLP on

The scheduled implementation date applicable for most financial end users for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules is March 1, 2017. In most cases, the U.S....more

CFTC Grants No Action Relief to EU Swap Dealers from Swap Documentation Rules

Demonstrating coordination between US swap rules and those of the European Union, the Commodity Futures Trading Commission issued a no action letter (no. 13-45) on July 11 that permits a company organized under the laws of...more

CFTC Extends Deadline to Comply with Certain Trading Documentation Requirements Under Dodd-Frank for Corporate End-Users of...

In late June 2013, the Commodity and Futures Trading Commission (CFTC) issued a no-action letter extending the period for certain corporate end-users of foreign exchange (FX) derivative transactions to comply with the trading...more

Portfolio Reconciliation and Swap Trading Relationship Documentation Requirements for SDs and MSPs

Provisionally registered swap dealers (SDs) and major swap participants (MSPs) are required by the National Futures Association (NFA) to submit portfolio reconciliation and swap trading relationship documentation policies and...more

What Every End-User Needs to Know About the ISDA March 2013 DF Protocol

by Holland & Knight LLP on

On March 22, 2013, ISDA published the March 2013 DF Protocol, and on May 20, 2013, ISDA Amend1 became available to accept Questionnaires under the new Protocol. The March 2013 Protocol (which is completely separate from the...more

ISDA March 2013 Dodd-Frank Protocol (a.k.a. Dodd-Frank Protocol 2.0)

by Shearman & Sterling LLP on

On March 22, 2013, ISDA published the March 2013 Dodd-Frank Protocol (the “Protocol” or “Protocol 2.0”), which is designed to facilitate compliance with certain CFTC rules relating to clearing, portfolio reconciliation and...more

DF Protocol Deadline is May 1, 2013

by Foley Hoag LLP on

Managers Who Use Swaps Should Act Now - Managers of funds and separately managed accounts that use swaps are reminded that they (or their clients) must complete the DF Protocol Adherence Letter and DF Protocol...more

The CFTC Issues Interim Final Rules Extending the Time for Compliance with Certain Business Conduct and Documentation Requirements...

by White & Case LLP on

On December 18, 2012, the US Commodity Futures Trading Commission’s (the “Commission”) approved interim final rules (the “Interim Final Rules”) for swap dealers (“SDs”) and major swap participants (“MSPs”) that delay...more

The CFTC Issues Interim Final Rules Extending the Time for Compliance for Certain Business Conduct and Documentation Requirements...

by White & Case LLP on

On December 18, 2012, the US Commodity Futures Trading Commission’s (the “Commission”) approved interim final rules (the “Interim Final Rules”) for swap dealers (“SDs”) and major swap participants (“MSPs”) that delay...more

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Cybersecurity

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