On October 15, the Commodity Futures Trading Commission adopted new rules on position limits. The new rules mark an important step forward in a decade-long journey to enact one of the remaining key provisions of Title VII of...more
The year 2020 has been a highly unusual and disruptive year — from the COVID-19 pandemic to natural disasters — our daily lives have changed dramatically. Most notable is the social awakening that has taken place this year...more
Eight years after the Commodity Futures Trading Commission (CFTC or Commission) established a comprehensive swap data reporting and public dissemination regulatory regime, on September 17, the Commission adopted extensive...more
Amid the recent, almost daily news of raging wildfires in the western United States and elsewhere, increasingly destructive and deadly hurricanes in the southeast, and record high temperatures in many locations around the...more
KEY POINTS -
- The Commodity Futures Trading Commission (CFTC) has finalized its proposed new rule (Final Rule) relating to the cross-border application of certain of its swap regulations.
- The Final Rule supersedes...more
Thanks to recent actions taken by the Commodity Futures Trading Commission (CFTC) and the five US prudential regulators responsible for the uncleared swap margin rules for bank swap dealers, most US end user participants in...more
SEC/CORPORATE -
SEC Adopts Amendments and Issues Guidance Related to Proxy Voting Advice -
On July 22, the Securities and Exchange Commission announced the adoption of amendments (the Amendments) to the SEC’s rules...more
Key Points -
- The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) recently released a Risk Alert warning investment advisers, broker-dealers, investment companies,...more
Recent rulings from federal courts enjoined the US Small Business Administration (SBA) from applying its April 2, 2020 Interim Final Rule (April 2 IFR) to limit the types of businesses that can participate in the Paycheck...more
Responding to recent COVID-19-related volatility in futures and options markets and their related agricultural, energy and financial cash markets, and the expectation that such volatility will continue, staff from the three...more
Key Points -
- On April 14, the Commodity Futures Trading Commission (CFTC) proposed an extensive set of amendments to its bankruptcy rules (Proposal), which have not been materially amended since the regulations were...more
The unprecedented havoc wreaked on world economies by COVID-19 has put all manner of entities under financial stress. If some of those entities are your counterparties to swaps under either the 1992 ISDA Master Agreement or...more
Key Points -
- The CFTC is proposing to eliminate large sections of current Form CPO-PQR.
- Revised Form CPO-PQR would have a quarterly filing requirement for all CPOs (regardless of size) and would ask them to provide...more
At least some financial markets and funds businesses are likely precluded from applying for the Paycheck Protection Program (PPP) under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) as a result of an...more
Key Points -
The widely publicized Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), providing an estimated $2 trillion dollars of COVID-19 relief to Americans, has passed both chambers of Congress and...more
Key Points -
- This Katten Advisory focuses on the impact of the COVID-19 outbreak on regulatory compliance obligations of financial firms operating in the United States, with a focus on securities and derivatives industry...more
3/21/2020
/ Business Continuity Plans ,
Centers for Disease Control and Prevention (CDC) ,
CFTC ,
Coronavirus/COVID-19 ,
Enforcement ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
National Futures Association ,
Relief Measures ,
Securities and Exchange Commission (SEC) ,
World Health Organization
Key Points
- The Commodity Futures Trading Commission (CFTC) has proposed new rules (Proposal) for the cross-border application of certain of its swap regulations.
- The Proposal includes certain changes relative to the...more
3/4/2020
/ CFTC ,
Collective Investment Schemes ,
Comment Period ,
Commodity Exchange Act (CEA) ,
Cross-Border Transactions ,
Derivatives ,
Employee Retirement Income Security Act (ERISA) ,
Foreign Branch Offices ,
Foreign Branches of U.S. Banks ,
Foreign Investment ,
Foreign Jurisdictions ,
Major Swap Participants ,
New Rules ,
Principal Place of Business ,
Public Comment ,
Securities and Exchange Commission (SEC) ,
Swap Dealers ,
Swaps
BROKER-DEALER -
FINRA Proposes to Ease Restrictions on Initial Equity Public Offerings and New Issues -
The Financial Industry Regulatory Authority (FINRA) is proposing to amend its Rule 5130 and Rule 5131 to...more
8/5/2019
/ Blockchain ,
CFTC ,
Financial Conduct Authority (FCA) ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Investment ,
Foreign Sovereigns ,
Initial Public Offering (IPO) ,
No-Action Letters ,
Proposed Amendments ,
Reporting Requirements ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
TRACE ,
UK
The National Futures Association (NFA) has proposed updated guidance (the Proposed Guidance) for all of its member firms—including futures commission merchants (FCMs), retail foreign exchange dealers (RFEDs), introducing...more