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Swaps Financial Markets Financial Services Industry

Proskauer - Regulatory & Compliance

CFTC Clarifies that FX Window Forwards are Not “Swaps”

On April 9, 2025, the Markets Participants Division and the Division of Market Oversight (collectively, the “Divisions”) of the Commodity Futures Trading Commission (the “CFTC”) published a Staff Letter (the “Staff Letter”)...more

Cadwalader, Wickersham & Taft LLP

A Decade-Long Death of Footnote 195

Sometimes a small footnote (which technically is not even a part of the official Federal rule) may have an outsize impact on the rule itself. In 2013, subsequent to the enactment of the Dodd Frank Act of 2010, the Commodity...more

Jones Day

Wait, There's More: The CFTC Proposes Additional Swap Reporting and Recordkeeping Amendments

Jones Day on

The Commodity Futures Trading Commission ("CFTC") has proposed swap reporting and recordkeeping amendments that would: designate a unique product identifier ("UPI") and product classification system ("PCS") for the "other...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

SEC Adopts Rules for Enhanced Regulatory Framework for Securities Clearing Agencies - On September 28, 2016 the Securities and Exchange Commission ("SEC") voted to adopt new rules to establish "enhanced standards for the...more

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