News & Analysis as of

Swap Dealers

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
WilmerHale

Want To Get Into CFTC-Regulated Event Contract Markets? Here’s How It Works

WilmerHale on

Event contracts—often referred to as “prediction markets”—are used by market participants to forecast elections, economic indicators, weather events, economic policy decisions and even sporting event outcomes. Other types of...more

Morgan Lewis

Crypto Clarity: CFTC FAQs Clarify Use of Crypto Assets by Registrants and Registered Entities – Part 2

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The CFTC’s Market Participants Division (MPD) and Division of Clearing and Risk (DCR) jointly issued on March 20, 2026 responses to 11 frequently asked questions addressing how futures commission merchants, derivatives...more

Lowenstein Sandler LLP

CFTC Responds to FAQs From FCMs, SDs, and DCOs Regarding Crypto Collateral

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On March 20, the CFTC’s Market Participants Division (MPD) and Division of Clearing and Risk (together, the Divisions) published FAQs clarifying registrant and registered entity activities relating to crypto assets under the...more

Katten Muchin Rosenman LLP

NFA Cuts the Red Tape: Non-US Swap Dealers Breathe Easier With Streamlined Cross-Border Amendments

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Sometimes the best regulatory changes are the ones that make compliance officers smile — and maybe even leave the office before 7:00 p.m. The National Futures Association (NFA) recently delivered just that, amending two key...more

Mayer Brown Free Writings + Perspectives

Harmony and Understanding? (Or at Least a Memorandum)

Mayer Brown Free Writings + Perspectives on

In back-to-back speeches at the Futures Industry Association conference, Commodity Futures Trading Commission Chair Selig and Securities and Exchange Commission Chair Atkins set out their views regarding facilitating...more

Eversheds Sutherland (US) LLP

CFTC Confirms Morgan Stanley Internal Merger Will Not Affect Status Of Legacy Swaps

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On January 30, 2026, the Commodity Futures Trading Commission (CFTC) issued Staff Letter 26‑03 (Staff Letter), providing clarity for swap market participants regarding the treatment of certain legacy swaps with two Morgan...more

Baker Botts L.L.P.

Commodity Futures Trading Commission (“CFTC”) Seeks to Expand Hedging Options for Energy End-Users

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On December 21, 2025, the CFTC’s Market Participants Division (“MPD”) issued a no‑action letter that could materially expand hedging options for commercial energy companies by allowing firms to exclude certain “Energy...more

Cadwalader, Wickersham & Taft LLP

CFTC Energy End-User Swaps Pilot Program Reflects Renewed Reassessment of Dodd-Frank Energy Market Constraints

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I. Executive Summary - On December 19, 2025, the CFTC’s Market Participants Division (“MPD”) issued Staff No-Action Letter No. 25-51, establishing a three-month pilot program under which certain energy commodity end-user...more

Moore & Van Allen PLLC

The Desk: January

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Enforcement Round-up - Wells and Investigative Process Enhancements.  On December 1, 2025, former Acting Chair Pham announced another significant enforcement-related policy change in what was a transformative year for the...more

Cadwalader, Wickersham & Taft LLP

A Year of Change Across Financial Regulation – and What Comes Next, December 2025 - CFTC Staff Issue Broad No-Action Relief...

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On December 9, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (the “Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) issued Staff Letter...more

Patomak Global Partners

CFTC Issues No-Action Relief for Swap Data Reporting Error Corrections

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On December 11, 2025, the Commodity Futures Trading Commission (CFTC) issued no-action relief regarding the correction of errors in swap transaction and pricing data submitted to a swap data repository (SDR)....more

Parker Poe Adams & Bernstein LLP

SEC Examination Priorities for 2026 Focus on Oversight and Conformity With Securities Laws

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The U.S. Securities and Exchange Commission Division of Examinations has released its 2026 examination priorities. The priorities address examination areas associated with each category of registrant: investment advisers,...more

Patomak Global Partners

SEC’s 2026 SBSD and SBSEF Examination Priorities: What Firms Should Expect and How to Prepare

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The Division publishes its annual examination priorities to provide transparency to registrants and investors about the topics it plans to focus on in the new fiscal year and to encourage firms to direct their compliance...more

Mayer Brown Free Writings + Perspectives

SEC Division of Examinations Announces 2026 Exam Priorities

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Under new SEC leadership, the Division’s 2026 Examination Priorities reflect a modified approach, following a reevaluation of the Division’s risk-based priorities, and a renewed focus on several traditional risk areas...more

Haynes Boone

Financial Regulatory Roundup November 2025

Haynes Boone on

SEC Chairman Atkins Issues Statement Regarding Security-Based Swap Dealer De Minimis Threshold Phase-in Period and Lookback Period - On Oct. 29, 2025, in light of the ongoing U.S. government shutdown, Securities and...more

Patomak Global Partners

SBSD De Minimis Threshold Phase-In: Potential Relief Ahead, but Firms Should Prepare for All Scenarios

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Situation Overview: The SEC’s temporary de minimis thresholds for security-based swap dealing activity ($8 billion for credit default swaps and $400 million for non-CDS) are scheduled to change following the expiration of the...more

Mayer Brown Free Writings + Perspectives

SEC Signals Incoming Relief for De Minimis Security-Based Swap Dealers

Mayer Brown Free Writings + Perspectives on

On October 29, 2025, Paul Atkins, Chairman of the Securities and Exchange Commission (“SEC”), signaled that he will ask SEC staff to evaluate relief for certain firms who engage in a de minimis level of security-based swap...more

Katten Muchin Rosenman LLP

If It’s Broken, Please Fix It: The CFTC Proposes to Resolve Compliance Challenges for Swap Dealers

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The Commodity Futures Trading Commission (“CFTC” or “Commission”) proposed targeted amendments (“Proposal”) to its business conduct and documentation requirements for swap dealers (“SDs”) on September 24. The Proposal is...more

Eversheds Sutherland (US) LLP

CFTC Proposes Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants

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On September 24, 2025, the Commodity Futures Trading Commission (CFTC) issued a notice of proposed rulemaking to revise its external business conduct standards and swap documentation requirements applicable to swap dealers...more

Moore & Van Allen PLLC

The Desk: October

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Happy October, the CFTC kept us very busy in September. Nonetheless, it’s time to plan your Halloween costume (unless like me, your children have already decided that for you). Options are Ghost of PTMMM (roams the halls...more

Katten Muchin Rosenman LLP

CFTC Staff Issues Relief Intended to Reduce Burdens of Swap Data Notification Requirements

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Staff from the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued No-Action Relief Letter 25-25 on July 31, 2025 to help ease compliance burdens placed on reporting counterparties in meeting the...more

Bracewell LLP

Derivatives and Securities Dealers' Pre-Hedging of Client Trades Faces Potential New Rules

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Derivatives and securities dealers and some of their market users are locked in a potentially consequential debate over what legal standards should be adopted to govern pre-hedging (also called “pre-positioning” or...more

Patomak Global Partners

CFTC Eases SDR Error Notification Requirements With New No-Action Relief

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Reporting counterparties must correct any error in their SDR reporting “as soon as technologically practicable” and, “[i]n all cases, […] within seven business days” after its discovery. If they fail to do so, they must...more

McDermott Will & Schulte

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

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On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Katten Muchin Rosenman LLP

Unpacking CFTC Letters 25-09 and 25-10

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Derivatives market participants continue to process the implications of two significant interpretive letters issued by the Commodity Futures Trading Commission (CFTC) staff earlier this year. Letter 25-09 effectively...more

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