Open for Business: SEF Competition Heating Up in the New Market Structure
An Update on SEF, IDB and Swap Regulation from Chris Ferreri of ICAP
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
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
The Commodity Futures Trading Commission (CFTC or Commission) has issued a series of eight staff letters which will facilitate the functioning of the derivatives markets during the COVID-19 pandemic. These actions will assist...more
The Commodity Futures Trading Commission has issued two no-action letters to ensure that existing regulatory relief and substituted compliance measures for EU firms will continue to apply to U.K. firms following the U.K.’s...more
BROKER-DEALER - Nasdaq Proposes Rule Change to SEC to Assume Operational Responsibility for Certain Investigation and Enforcement Functions Currently Performed by FINRA - On April 3, the Securities and Exchange...more
On May 30, 2017, the U.S. Commodity Futures Trading Commission‘s (“CFTC“) Division of Market Oversight and Division of Clearing and Risk issued a no-action letter extending the relief provided in CFTC Letter No. 16-58, which...more
The CFTC’s Division of Market Oversight (DMO) issued a no-action letter extending relief associated with swap trade confirmation requirements that previously was provided in CFTC Staff Letter 16-25, which expires March 31,...more
The Commodity Futures Trading Commission’s Division of Market Oversight has extended previously granted relief for Swap Execution Facilities (SEFs) with respect to requirements for certain transactions in uncleared swaps....more
On December 8, 2015, the U.S. Commodity Futures Trading Commission’s (the “CFTC”) Division of Swap Dealer and Intermediary Oversight and Division of Market Oversight issued a time-limited no-action letter extending the relief...more
On May 19, the Commodity Futures Trading Commission issued two no-action letters granting relief to certain swaps trading platforms in Australia and participants executing swaps transactions on such platforms....more
On September 30, the Commodity Futures Trading Commission’s Divisions of Market Oversight and Clearing and Risk (Divisions) issued No-Action Letter No. 14-121 extending no-action relief previously granted to swap execution...more
The Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight of the Commodity Futures Trading Commission have issued relief from certain recordkeeping obligations for persons that are not...more
In this issue: - SEC Issues Statement on the Effect of the Recent US Court of Appeals Decision on the Conflict Minerals Rule - CFTC Extends Relief From Oral Communication Recording Requirement - CFTC...more
The Commission responds to issues facing end-users as a result of derivatives reforms. Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the Commodity Exchange Act...more
On April 9, 2014, the Division of Market Oversight (DMO) and Division of Swap Dealer and Intermediary Oversight (DSIO) (together, the Divisions) of the United States Commodity Futures Trading Commission (CFTC) issued...more
The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight issued No-Action Letter No. 13-77, which extends the oral communications recording compliance...more
Commodity Futures Trading Commission staff released several no-action letters impacting swap execution facilities (SEFs) and their participants. These no-action letters are related to swap data reporting requirements, SEF...more
In this issue: - FINRA Proposes Rule to Require Alternative Trading Systems to Report Volume Information and Use Unique Market Participant Identifiers - SEC Issues Frequently Asked Questions Regarding Liability...more
On June 17, the CFTC Division of Market Oversight issued a no-action letter providing temporary relief to entities that have been operating pre-Dodd-Frank Act trading platforms....more
On June 17, the Commodity Futures Trading Commission’s Division of Market Oversight extended the no-action relief it previously granted to any person or entity offering, entering into, or rendering advice or services with...more