News & Analysis as of

Regulatory Requirements No-Action Letters Commodities Futures Trading Commission

Eversheds Sutherland (US) LLP

CFTC eases swap data error correction notification requirements

On July 31, 2025, the Commodity Futures Trading Commission’s Division of Market Oversight (CFTC) issued a no-action letter granting relief to reporting counterparties from the swap data reporting error correction notification...more

Katten Muchin Rosenman LLP

CFTC Staff Issues Relief Intended to Reduce Burdens of Swap Data Notification Requirements

Staff from the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued No-Action Relief Letter 25-25 on July 31, 2025 to help ease compliance burdens placed on reporting counterparties in meeting the...more

Katten Muchin Rosenman LLP

CFTC Issues No-Action Relief for SEFs on Order Book Obligations

In a marked departure from its position since 2013, the Commodity Futures Trading Commission (CFTC) issued No-Action Letter 25-24 on July 30, 2025 (Letter 25-24), stating that it will not recommend enforcement action against...more

Patomak Global Partners

CFTC Eases SDR Error Notification Requirements With New No-Action Relief

Reporting counterparties must correct any error in their SDR reporting “as soon as technologically practicable” and, “[i]n all cases, […] within seven business days” after its discovery. If they fail to do so, they must...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Provides No-Action Relief From Swap Data Error-Notification Requirements

- What is new: The CFTC’s Division of Market Oversight issued a no-action letter providing reporting counterparties relief from the requirement to report swap-reporting errors impacting less than 5% of their open swaps. -...more

Ropes & Gray LLP

Welcome Relief - CFTC Staff Extends No-Action Relief on Position Aggregation Requirements

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The Commodity Futures Trading Commission ("CFTC") Division of Market Oversight ("DMO") has issued relief (see CFTC Letter 21-21) extending the no-action positions previously granted with respect to certain position...more

Cadwalader, Wickersham & Taft LLP

Shifting Signals, April 2025 - Relief for Swap Dealer Pre-Trade Disclosures

On April 4, 2025, the staff of the Commodity Futures Trading Commission ("CFTC") Market Participants Division ("MPD") issued compliance relief for registered swap dealers ("SDs") from the requirement to provide the so-called...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

Katten Muchin Rosenman LLP

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

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

Latham & Watkins LLP

2020 Digital Asset Regulatory Lookback (US Edition)

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Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. Last year, Latham & Watkins sounded a hopeful note that 2020 would provide...more

Orrick, Herrington & Sutcliffe LLP

Extension of Brexit No-Action Letters

In November 2020, the CFTC published two no-action letters extending previously granted no-action relief related to Brexit. The relief was intended to provide “greater certainty to the global marketplace” in connection with...more

Morgan Lewis

CFTC Issues Additional Relief in Response to COVID-19

Morgan Lewis on

The US Commodity Futures Trading Commission recently issued more no-action letters in response to the coronavirus (COVID-19) pandemic, providing relief from capital requirements and fingerprint requirements....more

Skadden, Arps, Slate, Meagher & Flom LLP

An Illusory Promise or Real Change? Transition at CFTC Brings Hope for Dodd-Frank Act Revisions

Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more

Cadwalader, Wickersham & Taft LLP

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

Polsinelli

Wind of Change - The Year FinTech Came in From the Cold - Polsinelli BitBlog: Year End Edition

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Digital assets and Blockchain technologies which were once described as the tools of criminals, are now a key part of efforts by traditional financial services firms to transform their businesses and innovative firms looking...more

Polsinelli

CFTC Staff No-Action Relief Allowing Additional Swap Activity for a Bank Relying on the IDI Exclusion from Swap Dealer...

Polsinelli on

On August 28, 2018, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission (CFTC) released a staff no-action letter allowing an anonymous individual financial institution...more

Vedder Price

Investment Services Regulatory Update - November 2017

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more

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