News & Analysis as of

Swaps Reporting Requirements End-Users

Orrick, Herrington & Sutcliffe LLP

Derivatives in Review - April 2016

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

Orrick - Finance 20/20

CFTC Approves Final Rule to Amend the Trade Option Exemption by Eliminating Certain Reporting and Recordkeeping Requirements for...

Orrick - Finance 20/20 on

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

Cadwalader, Wickersham & Taft LLP

CFTC Adopts Final Trade Option Rule

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

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Proposes to Reduce Trade Option Reporting Requirements for Commercial End-Users"

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

Stinson - Corporate & Securities Law Blog

New Year Brings Changes To End User Reporting Requirements For Trade Options And Swaps

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

Eversheds Sutherland (US) LLP

Legal Alert: Nearly at the Buzzer, CFTC Affords End-Users Relief from Dodd-Frank Reporting Requirements

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

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Letters

Commodity Futures Trading Commission staff recently released three no-action letters providing relief relating to swap data reporting requirements with respect to trade options, inter-affiliate swaps and real-time reporting...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - April 12, 2013

In this issue: - SEC and CFTC Adopt Joint Rules to Help Protect Investors from Identity Theft - CME Block Trade Advisories Clarify Nonpublic Information Restrictions - CFTC Staff Issues No-Action Letters ...more

Skadden, Arps, Slate, Meagher & Flom LLP

"CFTC Delays April 10 Compliance Date for Many Swap Data Reporting Requirements"

On April 9, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight, responding to requests from multiple interested parties, issued a no-action letter (the No-Action Letter) extending the April...more

Stinson - Corporate & Securities Law Blog

CFTC Extends Compliance Dates For End User Swap Reporting

The CFTC has issued a no-action letter that effectively extends the dates for swap counterparties who are not swap dealers (SDs) or major swap participants (MSPs) to come into compliance with the agency’s reporting rules...more

Stinson - Corporate & Securities Law Blog

CFTC Issues Advisory Regarding Swap Reporting Requirements

The CFTC Division of Market Oversight has issued an advisory to remind market participants of the swap reporting requirements that are now, or soon to be, in effect. End users must be in compliance with the reporting rules...more

Stinson - Corporate & Securities Law Blog

IECA Releases Amending Agreement To Facilitate End User Compliance With CFTC Regulations

The International Energy Credit Association (“IECA”) has released a standardized agreement titled the “Dodd-Frank Act Representations and Reporting Amending Agreement” to facilitate end user compliance with the CFTC’s swap...more

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