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
The Commodity Futures Trading Commission ("CFTC") has proposed swap reporting and recordkeeping amendments that would: designate a unique product identifier ("UPI") and product classification system ("PCS") for the "other...more
In Short:
The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more
10/19/2023
/ Banks ,
Borrowers ,
Debt ,
Debt Collection ,
Debt Instruments ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Lenders ,
OCC ,
Proposed Rules ,
Subsidiaries
In Short -
The Situation: The Federal Deposit Insurance Corporation ("FDIC") has proposed significant amendments (the "Proposal") to its rule requiring covered insured depository institutions ("CIDIs") to prepare and file...more
In Short -
The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...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