Toward the end of 2018, the Commodity Futures Trading Commission (CFTC) proposed significant revisions to the framework governing swap trading through swap execution facilities (SEFs) and designated contract markets (DCMs)....more
On October 12, 2017, the Division of Clearing and Risk (Division) of the US Commodity Futures Trading Commission (CFTC) issued an interpretative letter in response to a request for clarification on whether payments of...more
CFTC Delays Reduction in Swap Dealer De Minimis Exception Threshold - On October 13, 2016, the Commodity Futures Trading Commission approved an Order delaying for one year the reduction of the threshold for determining...more
Section 705 of the Consolidated Appropriations Act, 2016, that was signed by President Obama on December 18, 2015, amends Section 2(h)(7)(D) of the Commodity Exchange Act and the equivalent provision in the Securities...more
On January 13, President Obama signed legislation that aligns the rules relating to swap clearing and mandatory margin for uncleared swaps so that any entity that qualifies for an exemption from clearing its swaps also is...more
The enactment of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and its implementation by the Commodity Futures Trading Commission (“CFTC”) has ushered in a new era of...more
On February 7, 2013, the US Department of Labor (DOL) issued Advisory Opinion 2013-01A (the “Advisory Opinion”), which provides guidance under the Employee Retirement Income Security Act of 1974 (ERISA) for employee benefit...more