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Market Participants Commodities Futures Trading Commission Financial Markets

Jones Day

CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

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A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

Davis Wright Tremaine LLP

CFTC Eliminates PTMMM Disclosure Requirements for Swap Entities

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

Cadwalader, Wickersham & Taft LLP

IOSCO’s Proposed Guidance on Pre-Hedging Practices

On November 21, 2024, International Organization of Securities Commissions (“IOSCO”) published a consultation report (the “Report”) to provide guidance on acceptable pre-hedging practices and soliciting feedback from market...more

Stikeman Elliott LLP

CSA Publish Derivatives Data Reporting Transition Guidance

Stikeman Elliott LLP on

Amendments to swap data reporting rules are expected to be implemented by the Commodity Futures Trading Commission (CFTC) in December 2022. The Canadian Securities Administrators (CSA) have issued guidance to market...more

Morgan Lewis

CFTC No-Action Relief for Registrant and Market Participant COVID-19 Response

Morgan Lewis on

Many Commodity Futures Trading Commission registrants and other market participants are responding to the coronavirus (COVID-19) pandemic by implementing business continuity plans that move personnel from their “normal...more

Herbert Smith Freehills Kramer

Opportunistic Strategies in the CDS Market: Market Manipulation and the Eye of the Beholder

Over the past several years, a number of transactions in the credit default swap (CDS) market have been scrutinized by the public, market participants and regulators. These transactions — which we have labeled as...more

Jones Day

Decision Time for the ISDA 2019 Narrowly Tailored Credit Events Protocol

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The Situation: The International Swaps and Derivatives Associations, Inc. ("ISDA") is in the process of amending its credit derivatives documentation to address concerns market participants and regulators have raised...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 49

In this issue: - Delaware Chancery Court Declines to Dismiss Fraud Claims Against Private Equity Fund and Directors - Agencies Amend Regulatory Capital and Liquidity Coverage Ratio Rules - FINRA Proposes...more

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