Podcast: CFTC Issues LIBOR Transition Relief for Swaps
Slick Transition: ICE Clear Europe’s Paul Swann Talks NYSE Integration
Open for Business: SEF Competition Heating Up in the New Market Structure
Open for Business: SEFs Navigate the New Regulatory Environment
CFTC’s Scott O’Malia Calls for a Plan of Action on Swap Data
Cross-Border Regulation of Swaps Update from ISDA's Robert Pickel (Part 1)
An Update on SEF, IDB and Swap Regulation from Chris Ferreri of ICAP
Jill Sommers Reflects on the CFTC, Dodd-Frank, and Her Future
CFTC Proposal Poses “Monumental” Challenge to FCMs
Prediction markets have rapidly moved into the mainstream of financial innovation. These markets are very flexible and allow users to take a position on the outcome of a wide array of events — from elections and sport events...more
On December 21, 2025, the CFTC’s Market Participants Division (“MPD”) issued a no‑action letter that could materially expand hedging options for commercial energy companies by allowing firms to exclude certain “Energy...more
Virtual power purchase agreements (VPPAs) are classified as swaps under the Commodity Exchange Act (CEA). All firms engaging in VPPAs are obligated to comply with certain CFTC regulations, including non-financial firms...more
It should come as no surprise that priorities have shifted at the Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”), particularly with the enforcement divisions at both agencies...more
On December 19, 2025, the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”) issued no-action relief from commodity pool operator (“CPO”) registration for SEC-registered...more
On December 9, 2025, the Market Participants Division, the Division of Clearing and Risk, and the Division of Market Oversight (the “Divisions”) of the U.S. Commodity Futures Trading Commission (“CFTC”) issued Staff Letter...more
On December 11, 2025, the Commodity Futures Trading Commission (CFTC) issued no-action relief regarding the correction of errors in swap transaction and pricing data submitted to a swap data repository (SDR)....more
On December 9, 2025, the staff of the Commodity Futures Trading Commission (“CFTC”) issued no-action relief to harmonize how the regulatory requirements for swaps are applied to trades involving certain non-US persons (“NAL...more
Many prediction market firms have sought to avoid state regulation by emphasizing how their services differ from traditional sports betting. They characterize their offerings as “event contracts” or “swaps,” which are only...more
On November 21, 2025, the Structured Finance Association, on behalf of the risk transfer market, received no-action relief on the issue of registration as a commodity pool operator (“CPO”) from the staff of the Division of...more
Enforcement Round-Up - With the longest government shutdown on record taking up nearly half of the month and Acting Chair Pham waiting to pass the baton to Mike Selig (who is quickly progressing through the confirmation...more
The federal government’s 43‑day shutdown — which ended with a late‑evening November 12 funding bill and next‑day return to duty for furloughed staff — imposed a near‑total pause on the Commodity Futures Trading Commission’s...more
The Commodity Futures Trading Commission (“CFTC” or “Commission”) proposed targeted amendments (“Proposal”) to its business conduct and documentation requirements for swap dealers (“SDs”) on September 24. The Proposal is...more
On September 24, 2025, the Commodity Futures Trading Commission (CFTC) issued a notice of proposed rulemaking to revise its external business conduct standards and swap documentation requirements applicable to swap dealers...more
Happy October, the CFTC kept us very busy in September. Nonetheless, it’s time to plan your Halloween costume (unless like me, your children have already decided that for you). Options are Ghost of PTMMM (roams the halls...more
In Part 1 of this three-part overview of the Commodity Futures Trading Commission (CFTC), we take a look at the basics of CFTC regulation, highlighting what you need to know about the agency and its jurisdiction....more
Reporting counterparties must correct any error in their SDR reporting “as soon as technologically practicable” and, “[i]n all cases, […] within seven business days” after its discovery. If they fail to do so, they must...more
On July 31, 2025, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for certain swap reporting counterparties that fail to submit a swap data error correction notification (“NAL 25-25”). This relief...more
Derivatives market participants and exchanges can breathe a little easier now that Staff of the Market Participants Division and the Division of Market Oversight of the Commodity Futures Trading Commission (CFTC or...more
The CFTC staff have issued interpretative guidance regarding the application of cross-border definitions under the CFTC’s regulatory regimes covering swaps, foreign futures and foreign options transactions, and foreign boards...more
On May 20, 2025, two divisions within the Commodity Futures Trading Commission (“CFTC”) — the Market Participants Division (“MPD”) and the Enforcement Division (“DOE”) — released procedures providing guidance on how the...more
Derivatives market participants continue to process the implications of two significant interpretive letters issued by the Commodity Futures Trading Commission (CFTC) staff earlier this year. Letter 25-09 effectively...more
On April 9, 2025, the Markets Participants Division and the Division of Market Oversight (collectively, the “Divisions”) of the Commodity Futures Trading Commission (the “CFTC”) published a Staff Letter (the “Staff Letter”)...more
March is over and all of our brackets are busted. We hope you have been enjoying, Moore & Van Allen’s very own, Jay Bilas’ coverage on ESPN. In this month’s newsletter we will walk you through the CFTC’s continued updates on...more
On March 11, 2025 at the 50th Annual International Futures Industry (“FIA”) Conference, Commodity Futures Trading Commission (“CFTC”) Acting Chairman Caroline Pham delivered a ground-breaking keynote covering administrative...more