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Swap Dealers CPOs

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

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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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Extends Phase 5 Compliance Date for Its Initial Margin Rules and Proposes More Regulatory Flexibility for Non-US Commodity...

On May 28, 2020, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved an interim final rule extending the Phase 5 compliance date for the Commission’s initial margin rules (Interim Final Rule)...more

Dechert LLP

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

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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

Dechert LLP

NFA Adopts Cybersecurity Guidance

Dechert LLP on

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

McGuireWoods LLP

Four Cybersecurity Ideas from CFTC Commissioner Bowen

McGuireWoods LLP on

On Sept. 17, 2015, Commissioner Sharon Y. Bowen of the U.S. Commodity Futures Trading Commission (CFTC) gave the keynote address for the International Swaps and Derivatives Association’s 2015 North American Conference in New...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Extends Registered Futures Association Membership Requirement to Introducing Brokers, Commodity Pool Operators and Commodity...

The Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule (“Final Rule”) that formally extends the existing registered futures association (“RFA”) membership requirement to registered introducing...more

K&L Gates LLP

Cybersecurity Update: National Futures Association Proposes Cybersecurity Guidance Setting Forth General Requirements for Member...

K&L Gates LLP on

The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more

McGuireWoods LLP

NFA Proposes Cybersecurity Guidance for Derivatives Traders

McGuireWoods LLP on

On August 28, 2015, the National Futures Association (NFA) submitted a proposed interpretative notice (Notice) to the Commodity Futures Trading Commission (CFTC) to require information systems security programs (ISSPs). If...more

Katten Muchin Rosenman LLP

NFA Proposes Amendments to Its Articles of Incorporation

On May 29, the National Futures Association provided notice to its members of the unanimous approval by the NFA Board of Directors (Board) of proposed amendments to NFA’s Articles of Incorporation. Subject to approval by...more

Eversheds Sutherland (US) LLP

CFTC Grants No-Action Relief to Commodity Pool Operators with Respect to Certain Insurance-Linked Securitization Vehicles

Toward the end of 2014, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) issued two letters affecting insurance-linked securitization vehicles: CFTC...more

Miller & Martin PLLC

CFTC Issues Additional Relief for Family Offices

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In November 2012, the CFTC's Division of Swap Dealer and Intermediary Oversight issued a no-action letter stating that the Division would not recommend that the CFTC take enforcement action against a family office for failure...more

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