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
The new year is here and with it two important developments in the derivatives markets for nonswap dealer clients to consider. The first development is the market response to the looming discontinuation of U.S. dollar LIBOR...more
On July 19, 2018, the International Swaps and Derivatives Association (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) published a white paper entitled "Initial Margin for Non-Centrally Cleared...more
With the Financial Conduct Authority (the “FCA”) announcing in July 2017, essentially, its intent to no longer persuade or compel panel banks to make LIBOR submissions by the end of 2021, the future of LIBOR, and its role in...more
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
On March 1, 2017, new rules adopted by U.S. Prudential Regulators and the Commodity Futures Trading Commission (CFTC) will require registered swap dealers to post and collect daily variation margin for over-the-counter,...more
The scheduled implementation date applicable for most financial end users for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules is March 1, 2017. In most cases, the U.S....more
On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol will help market participants implement the new variation...more
On May 26, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved a proposed supplement (“Supplemental Proposal”) to its December 2013 proposal to establish position limits on futures and economically...more
Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more
On March 16, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) approved a final rule that eliminates the reporting and recordkeeping requirements in current CFTC regulations for trade option counterparties that are...more
On March 16, the U.S. Commodity Futures Trading Commission approved a final rule that eliminated certain requirements “for trade option counterparties that are neither swap dealers nor major swap participants[.]”...more
On March 16, 2016, the Commodity Futures Trading Commission (“CFTC”) unanimously approved amendments to the rules applicable to certain physically-settled options referred to as “trade options.” This final rule substantially...more
Under the Margin Rules, swap dealers and major swap participants that do not have a prudential regulator (Covered Swap Entities, or CSEs) would be required to collect and post initial margin for uncleared swaps with financial...more
To clarify our intended audience, in the Financial Entity Update we will address issues germane to entities that trade swaps but are neither dealers nor commercial end users. This includes a broad and diverse group of...more
EBA Final Report on Guidelines on Triggers for Use of Early Intervention Measures Under BRRD - On May 8, the European Banking Authority (EBA) published its final report (EBA/GL/2015/03) on guidelines on triggers for the...more
Trade options are physically settled over-the-counter options on most deliverable commodities (e.g., agricultural, energy, or metals) where the buyer is a producer, processor, commercial user or merchant of the commodity...more
On November 26, CFTC issued a no-action letter providing additional relief for eligible treasury affiliates that enter into swaps that are subject to the clearing requirement in section 2(h)(1) of the Commodity Exchange Act...more
The Dodd-Frank Act permits certain end-users to elect to use an exception to the swap clearing requirements under certain conditions, which is referred to as the end-user exception. For public companies, the ability to elect...more
There were a number of new developments with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requirements for swaps in the latter part of 2013. This...more
The first half of 2014 will bring changes to the end user reporting requirements for trade options and swaps—namely, (1) the commencement of the annual Form TO reporting requirement for unreported trade options and (2) a...more
Last month, the U.S. Commodity Futures Trading Commission (CFTC) issued final interpretive guidance with respect to the cross-border application of the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (Dodd-Frank...more
The Commodity Futures Trading Commission (CFTC) recently adopted three final rules pursuant to Title VII of the Dodd-Frank Wall Street Reform and Customer Protection Act that impact the manner in which end-users’ cleared...more
The House recently passed four discrete bills that address particular issues with the derivatives provisions of Dodd-Frank, including legislation to ensure there is a clear end-user exemption and legislation to address the...more
Broc Romanek of TheCorporateCounsel.net recently described a member’s concerns that some companies were having on relying on the Dodd-Frank Act’s exemption for end-users for swaps entered into by treasury subsidiaries and...more
On the brink of the compliance date for arguably one of the most burdensome requirements that end-users face under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Commodity Futures Trading...more