News & Analysis as of

Swap Dealers Financial Services Industry No-Action Letters

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 -
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

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

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

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more

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