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Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - Key Takeaways From CFTC Acting Chairman Caroline Pham’s FIA Boca 50 Keynote

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On March 11, 2025 at the 50th Annual International Futures Industry (“FIA”) Conference, Commodity Futures Trading Commission (“CFTC”) Acting Chairman Caroline Pham delivered a ground-breaking keynote covering administrative...more

A&O Shearman

UK Financial Conduct Authority policy statement on reforming commodity derivatives regulatory framework

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The Financial Conduct Authority (FCA) has published a policy statement (PS25/1) on reforming the commodity derivatives regulatory framework. The policy statement sets out the FCA's response to feedback on its consultation...more

Katten Muchin Rosenman LLP

The CFTC Codifies the Letter 19-17 Compliance Processes Around Separately Margined Accounts

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In 2014, the Joint Audit Committee issued a Regulatory Alert insisting that futures commission merchant (FCM) clearing members treat separate accounts of the same beneficial owner as a single account for purposes of US...more

White & Case LLP

Debt-for-nature swaps: A viable alternative for vulnerable economies amid global challenges

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Debt-for-nature swaps convert debts of low- and middle-income countries, unable to service external debts, into commitments related to nature. In the face of recent geopolitical tensions, economic challenges and growing...more

Cadwalader, Wickersham & Taft LLP

CFTC Extends OCR Final Rule Relief

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On September 22, 2023, the Commodity Futures Trading Commission’s (the “CFTC” or the “Commission") Division of Market Oversight extended its no-action position regarding certain large trader reporting (“LTR”) obligations for...more

Bennett Jones LLP

Share Swaps and Break Fees: ASC Decision Provides Guidance on Break Fees and Disclosure of Swaps

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On December 21, 2021, a panel of the Alberta Securities Commission (ASC) published its written decision in Re Bison Acquisition Corp., 2021 ABASC 107. The decision followed a July 2021 hearing and oral ruling on...more

Jones Day

SEC Proposes Three New Rules for Securities-Based Swaps

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The SEC is considering new rules that would require public position reporting and other requirements for security-based swaps. On December 15, 2021, the SEC proposed three rules under the Securities Exchange Act to...more

Morgan Lewis

National Futures Association Proposes New Reporting Requirements for Commodity Pool Operators

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The National Futures Association (NFA) has proposed a new rule that would require registered commodity pool operators (CPOs) that are members of the NFA (CPO Members) to report to the NFA by 5:00 pm Central Time the next...more

Hogan Lovells

Energy and metals companies and funds beware: Your trading positions may be "limited"

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On 30 January 2020 the Commodity Futures Trading Commission (CFTC) approved on a 3-2 vote proposed rules addressing position limits on speculative derivatives (Position Limits Proposal). The Position Limits Proposal has a...more

Hogan Lovells

Documentation changes may be required for commercial end users, funds, and other financial end users

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The new year is here and with it two important developments in the derivatives markets for nonswap dealer clients to consider. The first development is the market response to the looming discontinuation of U.S. dollar LIBOR...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC and European Commission Make Progress on Cross-Border Agreements

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On October 13, 2017, the Commodity Futures Trading Commission (CFTC) announced two cross-border developments with the European Commission (EC) that take significant steps toward reconciling regulation of cross-border...more

Hogan Lovells

FCA Announces Discontinuation of LIBOR

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As you may know, on July 27, 2017 the UK's Financial Conduct Authority (FCA) chief executive Andrew Bailey announced that market participants should not rely on the London Interbank Offered Rate (LIBOR) being available after...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

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On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

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