On April 17, 2014, the Securities and Exchange Commission (SEC) proposed new regulations that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street Reform and Consumer...more
Market participants that enter into uncleared swaps should expect to receive notifications from swap dealer (SD) and major swap participant (MSP) counterparties regarding segregation of initial margin for swaps. Dodd-Frank...more
As of February 15, 2014, certain types of fixed-for-floating interest rate swaps must be executed on a swap execution facility (SEF) or a designated contract market (DCM), unless an exception applies (e.g., the commercial...more
Since the enactment of Dodd-Frank in 2010, the CFTC and the SEC have proceeded at different speeds to address previously unregulated markets for swaps and security-based swaps, respectively. The CFTC moved quickly to develop...more
On January 16, 2014, staff of the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (Division) announced that the first “made-available-to-trade” determination (MAT Determination) will become...more
In 2013, the Commodity Futures Trading Commission (CFTC) adopted final guidance describing the circumstances in which the Dodd-Frank Act requirements will apply to cross-border swap activities (Guidance). In conjunction with...more
On November 5, 2013, the Commodity Futures Trading Commission (CFTC) voted 3-1 to re-propose rules to establish speculative position limits for futures, options and economically equivalent swaps on certain agricultural, metal...more
Earlier this year, the Commodity Futures Trading Commission (CFTC) issued Cross-Border Guidance that set out the agency’s interpretation on the extent to which CFTC swap regulations would apply outside the U.S. The...more
The Commodity Futures Trading Commission (CFTC or Commission) recently adopted several rules to improve large trader reporting, facilitate segregation of customer swap margin and enhance customer protections for futures and...more
11/13/2013
/ CFTC ,
Commodity Exchange Act (CEA) ,
Customer Funds Protection ,
Derivatives Clearing Organizations ,
Dodd-Frank ,
Futures Commission Merchants (FCMs) ,
Major Swap Participants ,
Mandatory Clearing Requirements ,
Margin Requirements ,
Reporting Requirements ,
Segregation Requirements ,
Swap Dealers ,
Swaps
On September 12, 2013, the Commodity Futures Trading Commission (CFTC) published a concept release (Concept Release or Release) requesting information about current market practices relating to the use of automated trading...more
At a public meeting on July 12, 2013, the Commodity Futures Trading Commission (CFTC or Commission) adopted final guidance on how Dodd-Frank Act requirements will apply to cross-border swap activities (Guidance). In...more
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
On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk provided no-action relief (the No-Action Letter) from certain reporting requirements relating...more
All swap market participants, including commercial end-users, should be aware of the upcoming April 10 deadline for Commodity Futures Trading Commission (CFTC) swap reporting and recordkeeping requirements under Parts 43, 45...more
New Commodity Futures Trading Commission (CFTC) swaps clearing rules will force non-financial entities to stop uncleared trading of certain interest-rate swaps (IRS) and index credit default swaps (index CDS) starting on...more
The Department of Labor (DOL) recently issued a long-awaited advisory opinion (the Advisory Opinion) clarifying and confirming the ability of central counterparties (CCPs) and their clearing members (Clearing Members) to...more
Swaps trade in a global market. Title VII of the Dodd-Frank Act amended the Commodity Exchange Act (CEA) to impose a panoply of regulation on the swaps market mostly through regulations adopted by the Commodity Futures...more
The Commodity Futures Trading Commission (CFTC) has issued an interim rule to extend the compliance date with certain business conduct standards (BCS) and documentation rules for swap dealers and major swap participants. The...more
The Commodity Futures Trading Commission’s (CFTC) external business conduct standards (BCS) for swaps require compliance for registered swap dealers by January 1, 2013. To facilitate compliance with the BCS rules, the...more