News & Analysis as of

Swap Dealers Securities

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 -
Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Contributions to Florida Gov. Ron DeSantis’ Presidential Campaign Are Subject to Federal Pay-to-Play Rules

Florida Gov. Ron DeSantis filed paperwork on May 24, 2023, to run for president in the 2024 election. In light of his announcement, it is important to keep in mind that contributions made to or solicited on behalf of Gov....more

WilmerHale

The Securities and Exchange Commission’s Implementation of Title VII of the Dodd-Frank Act: Reviewing the Status of Security-based...

WilmerHale on

Gary Gensler served as Chair of the Commodity Futures Trading Commission (“CFTC”)from May 26, 2009 to January 3, 2014. He presided over the CFTC during the period that followed the 2008 financial crisis and led the CFTC...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

Troutman Pepper

Documentation for the New Swap Margin Rules and Thoughts for the Buy Side and End Users

Troutman Pepper on

Because of the implementation of new regulatory requirements relating to both variation and initial margin for swaps, swap documentation for many market participants is about to become much more complicated....more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - CTFC Approves Re-Proposal of Position Limits Regulation - On December 5, 2016, the U.S. Commodity Futures Trading Commission ("CFTC") unanimously approved to re-propose rules that...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - CFTC Division of Market Oversight Reminds Market Participants of the Upcoming Expiration of Certain No-Action Relief From the Ownership and Control Final Rule - On November 16,...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Financial Industry Developments - CFTC Announces Measures to Enhance Protection of Customer Funds - On August 8, 2016, the U.S. Commodity Futures Trading Commission (CFTC) announced three separate enhancements...more

Proskauer Rose LLP

U.S. Department of Labor Finalizes Fiduciary Definition and Conflict of Interest Rule

Proskauer Rose LLP on

On April 6, 2015, the U.S. Department of Labor (Department) issued its highly anticipated final rule addressing when a person is considered to be a fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA)...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters Relating to Swaps Trading Platforms in Australia

On May 19, the Commodity Futures Trading Commission issued two no-action letters granting relief to certain swaps trading platforms in Australia and participants executing swaps transactions on such platforms....more

Latham & Watkins LLP

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

Latham & Watkins LLP on

Dealers and major industry participants may be subject to new margin requirements beginning as early as December 1, 2015. Regulators are expected to finalize rules regarding margin requirements for uncleared swaps...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 26

In this issue: - Delaware Fee-Shifting Legislation Delayed - SEC Orders Securities Exchanges and FINRA to Develop Tick Size Pilot Plan - CFTC Extends Relief to FCMs from Certain Commingling Requirements ...more

Katten Muchin Rosenman LLP

CFTC Issues No-Action Relief Regarding Annual Reports by Chief Compliance Officers

The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued two no-action letters providing relief from certain chief compliance officer (CCO) annual report filing...more

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