News & Analysis as of

Swaps Reporting Requirements Trade Options

Cadwalader, Wickersham & Taft LLP

CFTC Extends OCR Final Rule Relief

On September 22, 2023, the Commodity Futures Trading Commission’s (the “CFTC” or the “Commission") Division of Market Oversight extended its no-action position regarding certain large trader reporting (“LTR”) obligations for...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

Latham & Watkins LLP

Dodd-Frank Almost 6 Years Later: Where Are We Now? Energy-Related Derivatives Regulation

Latham & Watkins LLP on

In the almost six years since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the US Commodity Futures Trading Commission (CFTC) has, in large part, finalized its rulemakings...more

Morrison & Foerster LLP

CFTC Proposes Relief from Trade Option Reporting and Recordkeeping Requirements for Commercial End Users

On April 30, 2015, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to the trade option exemption (the “Proposal”) that would reduce reporting and...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

Stinson - Corporate & Securities Law Blog

CFTC Responds To FAQ On Commodity Options

Today, the CFTC Division of Market Oversight published a response to frequently asked questions regarding commodity options, including reporting obligations with respect to trade options. The response clarified a few...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

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