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Reporting Requirements No-Action Letters

Morrison & Foerster LLP

Highlights of Recent CFTC Developments

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

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

Eversheds Sutherland (US) LLP

CFTC issues no-action letter regarding CME’s listing of event contracts

On July 22, 2025, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight and Division of Clearing and Risk issued a no-action letter (CFTC Letter No. 25-23) granting targeted regulatory relief to the...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

Mayer Brown

Everyone’s Human: CFTC Rationalizes Swap Error Reporting

Mayer Brown on

On July 31, 2025, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for certain swap reporting counterparties that fail to submit a swap data error correction notification (“NAL 25-25”). This relief...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

Cooley LLP

Corp Fin Continues to Make Reg A Offerings Easier to Conduct

Cooley LLP on

Last month, Corp Fin’s Office of Small Business Policy issued no-action relief to a company from the requirement to file an annual report on Form 1-K under Regulation A – despite the fact that the company didn’t qualify for...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

Bass, Berry & Sims PLC

[Webinar] ESG Outlook: Preparing for the 2025 Reporting Season - December 17th, 12:00 pm - 1:00 pm CST

Bass, Berry & Sims PLC on

Join Bass, Berry & Sims and leading environmental, social, and governance (ESG) along with corporate and securities thought leaders for the next installment of our ESG Impact Webinar series. As public companies prepare for...more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

Goodwin on

In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...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

Morrison & Foerster LLP

Financial Services Report, Fall 2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest Featuring Articles on FINRA TRACE Reporting Obligations and FCA Guidance on Cryptoassets

BROKER-DEALER - FINRA Proposes to Ease Restrictions on Initial Equity Public Offerings and New Issues - The Financial Industry Regulatory Authority (FINRA) is proposing to amend its Rule 5130 and Rule 5131 to ease ...more

Vedder Price

Practice Pointer: Informal Guidance from the SEC Staff Regarding Rule 30e-3’s Transition Period Requirements for Variable...

Vedder Price on

The staff of the Securities and Exchange Commission (SEC) has informally provided Vedder Price with key interpretive guidance clarifying the transition period disclosure requirements for issuers of variable insurance products...more

Perkins Coie

Preparing for the 2019 Public Company Reporting Season

Perkins Coie on

During 2018, the SEC issued rule updates and guidance that are intended to ease certain public reporting requirements and clarify the SEC’s position with respect to the shareholder proposal process. While the SEC is taking...more

A&O Shearman

SEC Staff Eases Fund Director Burdens

A&O Shearman on

For decades, mutual fund directors have turned to quarterly reports on affiliated cross trades, participation in affiliated underwritings and affiliated brokerage; the reports themselves state that the trades are in...more

Stinson - Corporate & Securities Law Blog

SEC Simplifies Filing of Broker-Dealer Annual Reports on EDGAR

The SEC has previously provided guidance on the filing of annual and supplemental reports required under Rule 17a-5 or Rule 17a-12 by broker-dealers or over-the-counter derivatives dealers on the SEC EDGAR system. However,...more

Orrick - Finance 20/20

No-Action Letter Issued Regarding the OCR Final Rule

Orrick - Finance 20/20 on

On April 8, the U.S. Commodity Futures Trading Commission’s (“CFTC”) Division of Market Oversight issued a no-action letter regarding the ownership and control final rule (the “OCR Final Rule”). The OCR Final Rule requires...more

Latham & Watkins LLP

CFTC Extends Trade Option Reporting Deadline to April 1, 2016

Latham & Watkins LLP on

The CFTC provides the market additional time to submit Form TO while considering further amendments to trade option reporting rules. On February 18, 2016, the US Commodity Futures Trading Commission's (the CFTC) Division...more

Orrick - Finance 20/20

U.S. Swap Dealers and Non-U.S. Major Swap Participants Under SDR Reporting Rules

Orrick - Finance 20/20 on

On November 9, the U.S. Commodity Futures Trading Commission’s (the “CFTC“) Division of Market Oversight issued a time-limited no-action letter extending the relief provided in CFTC Letter No. 14-141. The relief applies to...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps - On August 19, The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments to existing rules relating...more

Goodwin

Financial Services Weekly News Roundup - June 2015 #3

Goodwin on

Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

Katten Muchin Rosenman LLP

CFTC Staff Issues No-Action Relief From Certain Financial Reporting Requirements Applicable to Introducing Brokers

On January 23, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter regarding financial reporting requirements as they apply to foreign introducing...more

Stinson - Corporate & Securities Law Blog

Others May Seek Swap Reporting Delay Like Southwest

Reuters has an interesting article about a no-action letter the CFTC issued to Southwest Airlines to permit a 15 calendar day delay in reporting oil derivative transactions. Southwest apparently convinced the CFTC that rapid...more

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