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Swap Dealers De Minimis Claims

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 -
Morrison & Foerster LLP

CFTC Order Extends Application of Current De Minimis Threshold Until December 2019

Last week the Commodity Futures Trading Commission (“CFTC”) issued an order (the “De Minimis Order”) that pushes back by one year the date on which the CFTC may lower its swap dealer de minimis threshold, the amount of swap...more

Orrick - Finance 20/20

Commission Approves an Order Regarding Swap Dealer Registration De Minimis Exception

Orrick - Finance 20/20 on

On October 13, 2016, the U.S. Commodity Futures Trading Commission extended until December 31, 2018, the $8 billion swap dealer registration de minimis threshold. Unless it is further modified, the threshold will become $3...more

Morrison & Foerster LLP

CFTC Releases Its Final Staff Report on the Swap Dealer De Minimis Exception

Last month the Commodity Futures Trading Commission (“CFTC”) released the final report of its staff (the “Staff”) on the de minimis exception to the CFTC’s definition of “swap dealer” (the “Final Report”). That exception,...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

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