Theodore Kneller at Skadden, Arps, Slate, Meagher & Flom LLP

"Expiration of CFTC Cross-Border Exemption May Impact Non-US Swap Trading"

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

12/19/2013 / CFTC , Compliance , Cross-Border , Exemptions , Swaps

"EU Derivatives Trade Reporting Obligations to Begin on February 12, 2014"

Starting February 12, 2014, the European Market Infrastructure Regulation (EMIR) will require EU-counterparties to all derivative contracts, whether traded on or off exchange, to report certain trade information and details...more

11/15/2013 / CFTC , Compliance , Derivatives , Dodd-Frank , EMIR , EU , European Securities and Markets Authority (ESMA) , Reporting Requirements

"CFTC Deadlines Loom for Commercial End Users"

End users of swaps should be aware of three impending deadlines for complying with new Commodity Futures Trading Commission (CFTC) regulations....more

8/12/2013 / CDS , CFTC , Commercial End-User Exception , Commodity Exchange Act (CEA) , Deadlines , End-Users , IRS , Reporting Requirements

SEC Proposes Cross-Border Security-Based Swap Rules and Guidance

On May 23, 2013, the Securities and Exchange Commission (SEC) published in the Federal Register proposed rules and guidance for applying Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank)...more

5/25/2013 / CFTC , Cross-Border Transactions , Dodd-Frank , Securities and Exchange Commission (SEC) , Security-Based Swaps

"CFTC Delays April 10 Compliance Date for Many Swap Data Reporting Requirements"

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

4/11/2013 / CFTC , Dodd-Frank , End-Users , Legal Entity Identifiers , Major Swap Participants , No-Action Letters , Reporting Requirements , Swap Dealers , Swaps

"CFTC Issues No-Action Relief From Certain Inter-Affiliate Swap Reporting Requirements"

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

4/10/2013 / CFTC , GAAP , IFRS , No-Action Letters , No-Action Relief , Reporting Requirements , Subsidiaries , Swaps

"CFTC No-Action Letter Relieves End-Users of Part 45 Reporting for Trade Options"

On April 5, 2013, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight (DMO) provided end-users no-action relief (the No-Action Letter) from certain “trade option” reporting and recordkeeping...more

4/8/2013 / CFTC , End-Users , Exemptions , No-Action Letters , Recordkeeping Requirements , Trade Options

Impending Swap Reporting Requirements to Impact All Swap Market Participants

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

4/5/2013 / CFTC , Commodity Exchange Act (CEA) , Dodd-Frank , Reporting Requirements , Swap Data Repositories , Swap Market , Swaps

"New CFTC Swap Clearing Rules to Require Board Review and Approval of the Election to Rely on the 'Commercial End-User Exception'"

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

3/14/2013 / CFTC , Commercial End-User Exception , Credit Default Swaps , Derivatives Clearing Organizations , Dodd-Frank , Interest Rate Swaps , Mandatory Clearing Requirements , Swaps

Theodore Kneller

Skadden, Arps, Slate, Meagher & Flom LLP

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