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Swap Dealers Commodities

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 -
Holland & Knight LLP

CFTC Seeks Comments on Use of AI in Derivatives Markets

Holland & Knight LLP on

The Commodity Futures Trading Commission (CFTC) has issued a request for comment (RFC) seeking public input on the use of artificial intelligence (AI) in CFTC-regulated markets. The RFC – distributed jointly by the CFTC's...more

Dechert LLP

New CFTC DSIO Director Outlines Components of Regulatory Program Applicable to Asset Managers; Addresses Extension of the CFTC...

Dechert LLP on

Director Joshua B. Sterling of the CFTC’s Division of Swap Dealer and Intermediary Oversight (DSIO or Division) delivered several speeches in September and early October 2019, setting forth certain guiding principles and the...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on the Latest Swap Regulations and Position Limits

DERIVATIVES - See also “CFTC Extends Public Comment Period for Proposed Rules Pertaining to Cross-Border Clearing” and “CFTC and European Commission Issue Joint Statement Following Meeting on Cross-Border Derivatives...more

Morrison & Foerster LLP

The SEC’s Final Rule Regarding Price Quotes and Research Reports Relating to Security-Based Swaps

This month the Securities and Exchange Commission (“SEC”) issued a final rule (the “Final Rule”) that provides that certain communications relating to security-based swaps (either singular or plural, “SBS”) will not...more

Stinson - Corporate & Securities Law Blog

CFTC Approves Final Rule for Filing Chief Compliance Officer Annual Reports

The CFTC approved a final rule amending a CFTC regulation addressing the timing for filing chief compliance officer annual reports for certain registrants. The final rule amends CFTC regulation 3.3 to provide futures...more

Orrick, Herrington & Sutcliffe LLP

Derivatives In Review - October 2016

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

Cadwalader, Wickersham & Taft LLP

CFTC Issues Fourth Penalty for Inaccurate Large Trader Reporting of Swaps

On September 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) issued a fourth penalty for violations of its Swaps Large Trader Reporting (“Swaps LTR”) rule. This time, the penalty was...more

Cadwalader, Wickersham & Taft LLP

CFTC Staff Issues Final Swap Dealer De Minimis Exception Report

On August 15, 2016, Staff of the U.S. Commodity Futures Trading Commission (“CFTC”) published a final report regarding the de minimis exception from swap dealer registration (“Staff De Minimis Report”).  The Staff De Minimis...more

Cadwalader, Wickersham & Taft LLP

CFTC Issues $560,000 Penalty for Inaccurate Large Trader Reporting of Swaps

On July 6, 2016, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) fined Barclays Bank PLC (“Barclays”) $560,000 for inaccurate large trader reporting of swaps positions. This is the third and largest...more

Morrison & Foerster LLP

CFTC Issues Final Rules Regarding the Cross-Border Application of its Uncleared Swaps Margin Requirements - June 2016

On May 24, 2016, the Commodity Futures Trading Commission (“CFTC”) in a much anticipated action approved the issuance of final rules (“Final Rules”) regarding the cross-border application of its uncleared swaps margin...more

Foley Hoag LLP - Security, Privacy and the...

CFTC Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs...more

Katten Muchin Rosenman LLP

Bridging the Week - September 2015 #2

CFTC Says Virtual Currencies Are a “Commodity” Under Federal Law, Files Charges Against Coinflip for Operating an Unregistered Bitcoin Options Trading Platform - The Commodity Futures Trading Commission filed and...more

Morrison & Foerster LLP

CFTC Issues Proposed Rules Regarding the Cross-Border Application of its Uncleared Swaps Margin Requirements

On June 29, 2015, the Commodity Futures Trading Commission (“CFTC”) issued proposed rules (“Proposed Rules”) regarding the cross-border application of its proposed uncleared swaps margin rules issued last October. The...more

Katten Muchin Rosenman LLP

Bridging the Week - June 2015 #4

Investment Adviser Chief Compliance Officer Blamed in SEC Lawsuit for President’s Theft of Client Funds; SEC Commissioner Criticizes Enforcement Actions Against CCOs Generally - The Securities and Exchange Commission...more

McGuireWoods LLP

Swaps End-User Update CFTC Proposes Reporting and Recordkeeping Relief for Commodity Trade Options

McGuireWoods LLP on

On April 30, 2015, the U.S. Commodity Futures Trading Commission (CFTC) approved a notice of proposed rulemaking (Proposed Rules) to reduce reporting and recordkeeping obligations for end-users that use commodity trade...more

Latham & Watkins LLP

UPDATE: Swap Dealers Will Face Significant Challenges from Reproposed Margin Rules for Uncleared Swaps

Latham & Watkins LLP on

Note: This version includes an additional section on the Terrorism Risk Insurance Program Reauthorization Act of 2015, which amends certain provisions of the Dodd-Frank Act to exempt certain counterparties from the initial...more

K&L Gates LLP

CFTC Provides Streamlined No-Action Relief Filing Procedure to Certain Commodity Pool Operators Who Delegate Responsibilities to...

K&L Gates LLP on

The Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (“CFTC” or the “Commission”) recently issued CFTC Letter No. 14-69 (May 12, 2014) (the “Letter”), which...more

Katten Muchin Rosenman LLP

CFTC Proposes to Amend De Minimis Threshold for Swaps with Utility Providers

The Commodity Futures Trading Commission has proposed to amend the “special entity” de minimis exception from swap dealer designation to exclude certain swaps with public utility providers. The proposed regulations are...more

Burr & Forman

Dodd-Frank News: May 2014: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

Burr & Forman on

In This Issue: - RECENT CASES ..Preemption ..CFPB Involvement in Litigation ..CFTC Regulation of Retail Commodity Transactions ..Durbin Amendment ..Appraiser Disclosure Requirements Under...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Proposes Three Actions to Address Rulemaking Issues"

On May 22, 2014, the Commodity Futures Trading Commission (Commission or CFTC) and its staff took three actions. First, the Commission proposed to amend its existing definition of “swap dealer” in order to allow...more

Katten Muchin Rosenman LLP

CFTC Reissues FAQ on Commodity Options

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has reissued a document addressing frequently asked questions (FAQs) on commodity options. The FAQs document, which DMO originally issued on...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review - April 2, 2013

In This Issue: *Financial Industry Developments - CFTC No-Action Relief for Commodity Trader Advisor Registration - CFTC Regulations on Associated Persons of Swap Dealers and Major Swap Participants -...more

Eversheds Sutherland (US) LLP

Legal Alert: The CPO and CTA Regulatory Regimes: What Operators of and Advisers to Commodity Pools Should Expect in 2013

There were a number of significant changes to the regulatory regime for commodity pool operators (CPOs) and commodity trading advisors (CTAs) in 2012. As a result of these changes, various types of collective investment...more

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