A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more
6/2/2025
/ CFTC ,
Commodity Exchange Act (CEA) ,
Cross-Border Transactions ,
Derivatives ,
Enforcement Actions ,
Financial Markets ,
Financial Services Industry ,
Interpretive Letters ,
Investment Portfolios ,
Jurisdiction ,
Market Participants ,
New Guidance ,
Popular ,
Regulatory Oversight ,
Regulatory Requirements ,
Settlement
On April 17, 2025, the Commodity Futures Trading Commission's ("CFTC") operating divisions ("Divisions") provided guidance in an advisory on the criteria they will use when determining whether to refer self-reported...more
The Commodity Futures Trading Commission's ("CFTC") new enforcement advisory introduces several major changes in policy and a matrix helping those facing potential or actual CFTC investigations quantify the extent to which...more
The Consumer Financial Protection Bureau (“CFPB”), Department of Health and Human Services (“HHS”), and United States Treasury have issued an interagency Request for Information (“RFI”) focused on the offering and provision...more
The proposed powers for the Financial Conduct Authority ("FCA") to manage the London Interbank Offered Rate ("LIBOR") transition should address so-called "tough legacy" contracts involving UK participants but could also have...more
The Situation: The International Swaps and Derivatives Association ("ISDA") is in the midst of consulting the market on a wide variety of issues to develop "triggers" and "fallbacks" related to LIBOR cessation. Thus far,...more
The Situation: SFIG's LIBOR Task Force has released the first of a planned series of "green papers" on benchmark transition in the US securitization market.
The Result: The Green Paper contains proposed recommendations...more