News & Analysis as of

Swap Dealers No-Action Relief Swaps

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 -
A&O Shearman

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

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The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more

Latham & Watkins LLP

CFTC Issues No-Action Relief for Derivatives Market IBOR Transition

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While not unlimited, the relief is welcome for counterparties seeking to transition to risk-free rates for legacy swaps. The US Commodity Futures Trading Commission (CFTC) has issued no-action relief to help market...more

K&L Gates LLP

CFTC Issues No-Action Relief for Floor Traders to Exclude SEF-Executed Cleared Swaps from the Swap Dealer De Minimis Calculation

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Introduction - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for floor traders to “encourage new liquidity providers to trade cleared swaps on registered venues without...more

A&O Shearman

US Commodity Futures Trading Commission Provides Margin Relief for Legacy Swaps

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In response to a request from the International Swaps and Derivatives Association, the Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight issued no-action relief that will permit swap...more

Orrick - Finance 20/20

DSIO Issues Time-Limited, Conditional No-Action Relief for Excluding Certain Loan-Related Swaps from Counting toward the Swap...

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (“DSIO“) announced “conditional, time-limited no-action relief to a banking entity for not counting...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

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On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more

Orrick - Finance 20/20

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements

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On November 14, 2017, the U.S. Commodity Futures Trading Commission’s Division (“CFTC“) of Market Oversight extended time-limited no-action relief to swap execution facilities (“SEFs“) from certain requirements under the...more

Orrick - Finance 20/20

CFTC Staff Extends Time-Limited No-Action Relief on the Applicability of Transaction-Level Requirements in Certain Cross-Border...

On July 25, 2017, the U.S. Commodity Futures Trading Commission (the “CFTC“) “issued a time-limited no-action letter that extends relief to swap dealers [] registered with the CFTC that are established under the laws of...more

Orrick, Herrington & Sutcliffe LLP

Derivatives In Review - May 2017

CME and LCH Amend Rulebooks on Variation Margin - Market participants historically have characterized cleared derivatives as being "collateralized-to-market", treating variation margin transfers as daily collateral...more

McGuireWoods LLP

CFTC Zeros in on Large Trader Reporting

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On September 17, 2015, the Commodity Futures Trading Commission (CFTC) issued an order filing and simultaneously settling charges against Australia and New Zealand Banking Group Ltd. (ANZ), an Australia-based firm that’s...more

Katten Muchin Rosenman LLP

CFTC Extends Relief for Non-US Swap Dealers From Transaction-Level Requirements

On August 13, the Division of Swap Dealer and Intermediary Oversight, Division of Clearing and Risk, and Division of Market Oversight of the Commodity Futures Trading Commission extended no-action relief from certain...more

Orrick - Finance 20/20

CFTC Extends No-Action Relief to Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations

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On June 15, CFTC Division of Market Oversight published a letter extending the time-limited relief provided by previously issued no-action letter 14-90, expiring on June 30, 2015, to June 30, 2016. The relief applies to the...more

Katten Muchin Rosenman LLP

CFTC Further Extends Valuation Data Reporting Relief for SDs and MSPs

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has further extended no-action relief from the valuation data reporting requirements for cleared swaps under CFTC Regulation 45.4(b)(2)(ii)....more

Goodwin

Financial Services Weekly News Roundup - June 2015 #3

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Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

Katten Muchin Rosenman LLP

CFTC Issues Relief From IB and CTA Registration to Foreign Persons Dealing in Swaps for International Financial Institutions

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief from introducing broker (IB) and commodity trading advisor (CTA) registration to persons...more

Cadwalader, Wickersham & Taft LLP

CFTC Issues No-Action Relief for Amended Legacy Swaps between SDs and SPVs

On March 31, 2015, the Division of Swap Dealer and Intermediary Oversight (the “Division”) of the Commodity Futures Trading Commission (the “CFTC”) issued no-action relief regarding compliance with certain of its swap...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

Katten Muchin Rosenman LLP

CFTC Extends No-Action Relief for Certain Transaction-Level Requirements for Non-US Swap Dealers

On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 23

In this issue: - SEC Chair Gives Speech on Equity Market Structure - New CFTC Commissioners Confirmed; Chairman Sworn In - CFTC Extends No-Action Relief for Certain Transaction-Level Requirements...more

K&L Gates LLP

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

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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

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

CFTC Announces New Approach for Considering Requests for Relief from Registration for Delegating Commodity Pool Operators - On May 12, CFTC Division of Swap Dealer and Intermediary Oversight announced a streamlined...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Staff Issues Long-Awaited CPO Delegation Relief"

On May 12, 2014, the Division of Swap Dealer and Intermediary Oversight (Division) of the Commodity Futures Trading Commission (CFTC) released its long-awaited commodity pool operator (CPO) delegation no-action letter...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 6

In this issue: - SEC Division of Corporation Finance Issues Guidance on Rule 506(c) Private Placements - SEC Issues No-action Relief Regarding Registration of M&A Brokers - CFTC Issues Guidance on New...more

Katten Muchin Rosenman LLP

CFTC Extends Relief from De Minimis Exception to Certain Non-US Affiliates

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued no-action relief to non-US persons that are not guaranteed or conduit affiliates of US persons (Non-Guaranteed Non-US...more

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