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Swap Dealers › Commodities Futures Trading Commission › Broker-Dealer

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
McDermott Will & Schulte

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

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On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - February 2024 - 2

Davis Wright Tremaine LLP on

Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Guidepost Solutions LLC on

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

BakerHostetler

SEC and CFTC Show No Signs of Slowing Down Enforcement Actions for Financial Firms’ Use of Off-Channel Communications

BakerHostetler on

The settlements announced by the SEC and CFTC on Monday are a continuation of the regulators’ focus on off-channel communications by employees of registered entities....more

Skadden, Arps, Slate, Meagher & Flom LLP

Contributions to Florida Gov. Ron DeSantis’ Presidential Campaign Are Subject to Federal Pay-to-Play Rules

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Florida Gov. Ron DeSantis filed paperwork on May 24, 2023, to run for president in the 2024 election. In light of his announcement, it is important to keep in mind that contributions made to or solicited on behalf of Gov....more

Sheppard Mullin Richter & Hampton LLP

SEC Off-Channel Communications Sweep

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Over the last several years, the Securities and Exchange Commission (the “SEC”) and the Commodities Futures Trading Commission (“CFTC”) have been laser-focused on the use of so called “off-channel communications” in the...more

Eversheds Sutherland (US) LLP

Enforcement appears as messages disappear part II: Steep penalties imposed in personal messaging cases  

Eversheds Sutherland (US) LLP on

On September 27, 2022, 15 broker-dealers and one investment adviser agreed to pay more than $1.8 billion in total civil penalties to the US Securities and Exchange Commission (SEC), and, for those same companies or affiliates...more

Katten Muchin Rosenman LLP

Key Takeaways: CFTC's FY 2021 Swap Dealers Enforcement Actions

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In Fiscal Year 2021 (FY 2021), the Commodity Futures Trading Commission (CFTC) brought and settled five enforcement actions against swap dealers for alleged reporting, disclosures and supervision failures. Historically, the...more

Sheppard Mullin Richter & Hampton LLP

Security-Based Swap Rules for End-Users

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As of November 1, 2021, dealers in security-based swaps (“SBS”) whose dealing activity exceeds certain de minimis thresholds (e.g., gross notional amount of $3 billion for credit default SBS, $150 million for other SBS, and...more

Moore & Van Allen PLLC

CFTC's first release in SOFR First Transition Initiative series on LIBOR and SOFR swaps

Moore & Van Allen PLLC on

In a press release on June 8th, the Commodity Futures Trading Commission (the “CFTC”) published its first release in a series called the “SOFR First Transition Initiative” as a best practice. One goal for this sort of “best...more

A&O Shearman

CFTC Approves Final Rule on Post-Trade Name Give-Up on Swap Execution Facilities

A&O Shearman on

The CFTC has adopted a final rule to prohibit the controversial practice of post-trade name give-up for swaps that are executed anonymously through a Swap Execution Facility (SEF) and are intended to be cleared. Although the...more

WilmerHale

The SEC Adopts Security-Based Swap Rules Governing Risk Mitigation Techniques for Uncleared Security-Based Swaps

WilmerHale on

On December 18, 2019, the Securities and Exchange Commission (the SEC or Commission) adopted new rules pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) requiring the...more

WilmerHale

The SEC's Security-Based Swap Recordkeeping and Reporting Rules

WilmerHale on

On September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major...more

Katten Muchin Rosenman LLP

Bridging The Week - January 2020

Katten Muchin Rosenman LLP on

It was not part of the recently concluded Golden Globes ceremony, but last week both the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations and the Financial Industry Regulatory Authority...more

Katten Muchin Rosenman LLP

Bridging The Week - December 2019 #2

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The New York State Department of Financial Services proposed a self-certification regime for the approval of new digital coins by licensed virtual currency firms similar to the process applied by the Commodity Futures Trading...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on CFTC Approves Final and Proposed Rules on Rulemaking and Capital...

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BROKER-DEALER - SEC Issues Guidance on Substituted Compliance Applications by Non-US Security-Based Swap Dealers and Major Security-Based Swap Participants - On November 25, the Securities and Exchange Commission’s...more

Katten Muchin Rosenman LLP

Bridging the Week - November 2019 #2

Katten Muchin Rosenman LLP on

A social media company and its wholly owned subsidiary sued by the Securities and Exchange Commission for conducting an offering of an unregistered digital security claimed that the agency was wrong in its characterization of...more

A&O Shearman

SEC Finalizes Capital, Margin and Segregation Requirements

A&O Shearman on

As a further step towards the implementation of its security-based swap regime, the Securities and Exchange Commission (SEC) has adopted a number of long-awaited capital, margin and segregation requirements for security-based...more

Katten Muchin Rosenman LLP

Bridging the Weeks - October 2019

Katten Muchin Rosenman LLP on

Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more

Katten Muchin Rosenman LLP

Bridging The Week - September 2019 #4

Katten Muchin Rosenman LLP on

Both the Commodity Futures Trading Commission and the Chicago Board of Trade settled related disciplinary actions for speculative position limits violations. The CFTC sanctioned the trading firm while the CBOT sanctioned the...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on the Latest Swap Regulations and Position Limits

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DERIVATIVES - See also “CFTC Extends Public Comment Period for Proposed Rules Pertaining to Cross-Border Clearing” and “CFTC and European Commission Issue Joint Statement Following Meeting on Cross-Border Derivatives...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on FINRA's Stock Fraud Warning to Investors after Hurricane Dorian, New...

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BROKER-DEALER - FINRA Warns Investors of Potential Stock Fraud in Wake of Hurricane Dorian - The Financial Industry Regulatory Authority (FINRA) recently released an investor alert cautioning investors of potential...more

WilmerHale

The SEC Adopts Security-Based Swap Rules Governing Capital, Margin and Segregation

WilmerHale on

On June 21, 2019, the Securities and Exchange Commission (SEC or Commission) adopted a package of rules and rule amendments (Rules) that set forth the capital, margin and segregation requirements for security-based swap...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on Additional Rules for Security-Based Swaps, Cross-Border Regulatory...

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SEC/CORPORATE - SEC Adopts Additional Rules for Security-Based Swaps - On June 21, the Securities and Exchange Commission adopted a panoply of final rules dealing with the following aspects of the regulation of...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on a FINRA Warning on Imposter Websites and Proposed Rules Changes on...

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BROKER-DEALER - SEC Extends Compliance Date for Regulation NMS Changes - The Securities and Exchange Commission has extended the compliance dates for amendments to Rule 606 of Regulation National Market System (NMS)...more

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