The Commodity Futures Trading Commission (CFTC) recently announced several new staff letters and public statements with material consequences for legal and business professionals in the derivatives markets. In this alert, we...more
The Commodity Futures Trading Commission (CFTC) is proposing a significant, new reporting burden on swaps reporting parties and on swaps data repositories (SDRs). The proposal would impose new requirements on SDRs to verify...more
The US Commodity Futures Trading Commission announced the signing of a Memorandum of Understanding with the European Securities and Markets Authority regarding cooperation with respect to recognized central counterparties...more
SEC/CORPORATE - DC Circuit Court Rejects States’ Challenge of Blue Sky Preemption Under Regulation A+ - On June 14, the Federal Court of Appeals for the District of Columbia (the DC Circuit) rejected challenges...more
Following on a joint statement by the Commodity Futures Trading Commission and European Commission announcing a common approach to the regulation of central counterparties (CCPs), the CFTC published a comparability...more
Industry Comments to Regulation AT Argue CFTC Proposed Rules Too Prescriptive; Registration and Source Code Requirements Particularly Objectionable - After declining multiple requests to extend the comment period that...more
Despite the consensus reached over six years ago among G-20 regulators on general principles for derivatives regulation, implementation of those principles in cross-border contexts has not always been smooth. ...more
On August 27, the European Securities and Markets Authority (ESMA) published a discussion paper (Discussion Paper) on the review of Article 26 of ESMA’s Regulatory Technical Standards (153/2013) (RTS) under the European...more
On August 6, the European Commission (EC) adopted new rules in the form of a delegated regulation (Delegated Regulation) requiring the mandatory clearing of certain over-the-counter (OTC) interest rate derivatives contracts...more
On May 11, 2015, the European Securities and Markets Authority (ESMA) published a fourth consultation paper (ESMA/2015/807) on the clearing obligation under EMIR (the Regulation on OTC derivative transactions, central...more