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Disclosure Requirements › Financial Services Industry › Swap Dealers

Davis Wright Tremaine LLP

CFTC Eliminates PTMMM Disclosure Requirements for Swap Entities

Davis Wright Tremaine LLP on

On April 4, 2025, the CFTC's Division of Market Participants issued No-Action Letter 25-09 regarding the controversial Pre-Trade Mid-Market Mark ("PTMMM") requirements in CFTC Regulation 23.431, effectively eliminating the...more

Katten Muchin Rosenman LLP

After 12 Enforcement Actions and 9 No-Action Letters, CFTC Staff Effectively Repeals the Pre-Trade Mid-Market Mark Disclosure...

Katten Muchin Rosenman LLP on

The Commodity Futures Trading Commission's (CFTC or Commission) Market Participants Division (MPD) issued Letter 25-09, which effectively eliminates the pre-trade mid-market mark (PTMMM) disclosure requirement for uncleared...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Orrick, Herrington & Sutcliffe LLP on

Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more

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