News & Analysis as of

Swap Execution Facilities Dodd-Frank Wall Street Reform and Consumer Protection Act

Cadwalader, Wickersham & Taft LLP

A Decade-Long Death of Footnote 195

Sometimes a small footnote (which technically is not even a part of the official Federal rule) may have an outsize impact on the rule itself. In 2013, subsequent to the enactment of the Dodd Frank Act of 2010, the Commodity...more

Jones Day

The CFTC Proposes Expansive Business and Governance Rules for Registered Derivatives Markets

Jones Day on

The Commodity Futures Trading Commission ("CFTC") recently proposed new and modified conflicts of interest, fitness, and governance regulations for swap execution facilities ("SEFs") and designated contract markets ("DCMs")....more

Cadwalader, Wickersham & Taft LLP

Expanding Regulatory Reach over Intermediaries That May Constitute Regulated Exchanges

In response to changes in business practices, regulations and laws eventually change, too.  During the past few years derivatives markets are witnessing this change as it applies to trading facilities as well as to entities...more

Cadwalader, Wickersham & Taft LLP

CFTC’s Swap Reporting Advisory

Accurate and timely reporting of swap data is the cornerstone of swap regulation. The CFTC had promulgated its swap reporting rules in 2012, and were after 2012 among the first rules implementing the Dodd-Frank Act to...more

Morgan Lewis

Final CFTC Rules Prohibit Post–Trade Name Give-Up for Swaps

Morgan Lewis on

The US Commodity Futures Trading Commission adopted final rules on June 25 prohibiting post–trade name give-up for anonymously executed and intended-to-be-cleared swaps effected on swap execution facilities....more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes To Ease Certain Swap Execution Facility Rules

On January 30, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved proposed amendments (SEF Proposed Rules) to CFTC regulations related to the execution of package transactions, the correction of error...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

K&L Gates LLP on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: Significant Regulatory, Jurisdictional and Enforcement Challenges Ahead for CFTC

In 2018, the Commodity Futures Trading Commission (CFTC or Commission) began operating with a full complement of five commissioners for the first time since 2014. Soon thereafter, it held a rare open meeting to propose major...more

A&O Shearman

CFTC Chair Outlines Further Steps to Swaps Trading Rules Reform

A&O Shearman on

On April 26, 2018, Commodity Futures Trading Commission (CFTC) Chairman J. Christopher Giancarlo and Chief Economist Bruce Tuckman published a white paper on potential reforms to the CFTC’s swaps trading rules....more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC and DOJ File a Flurry of Spoofing Actions

On January 29, 2018, the Commodity Futures Trading Commission (CFTC) announced the filing of eight anti-spoofing enforcement actions: three settlements with financial institutions and five complaints filed in federal district...more

A&O Shearman

US Commodity Futures Trading Commission Reproposes Position Limits Rule and Finalizes Aggregate Positions Rule

A&O Shearman on

The Commodity Futures Trading Commission voted unanimously to repropose regulations implementing limits on speculative futures and swaps positions as called for in the Dodd-Frank Act. In a separate vote, the CFTC approved...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - CTFC Approves Proposed Rules Addressing Application of Certain CEA Regulations to Cross-Border Transactions - On October 11, 2016, the U.S. Commodity Futures Trading Commission...more

Morrison & Foerster LLP

Dodd-Frank at 4: Where do we go from here?

Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more

Troutman Pepper

Landmark Swap Rules Adopted By CFTC

Troutman Pepper on

At its Twenty-Ninth Meeting to consider rulemaking under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2012 (Dodd-Frank) on May 16, 2013, the U.S. Commodities Futures Trading Commission (CFTC) adopted three...more

Katten Muchin Rosenman LLP

CFTC Approves Conforming Rules on Registration of Intermediaries

On August 17, the Commodity Futures Trading Commission approved rule amendments to conform its existing intermediary registration rules to changes made to the Commodity Exchange Act (CEA) by the Dodd-Frank Wall Street Reform...more

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