Dodd-Frank Derivatives
CFTC Announces Proposed Rulemaking Schedule
Derivatives The CFTC has announced a proposed rulemaking schedule. Some of the highlights include: The end-user exemption and other matters related to mandatory clearing are scheduled for June 2012 A proposed response to the MF Global collapse related to segregation and bankruptcy is scheduled for Fall 2012 Final rules for margin and capital for non-banks is [...] Read more →
CFTC and SEC Approve Final Rule Defining “Swap Dealer”
Banking, Derivatives, Energy By a 4-1 vote today, the CFTC approved release of a rule defining the terms “swap dealer” (“SD”), “major swap participant” (“MSP”), and eligible contract... Read more →
SEC Staff Analysis of Market Data Related to Credit Default Swap Transactions
Derivatives The SEC staff has made available an analysis of market data related to credit default swap transactions. The analysis, which was conducted by the staff of the SEC’s Division... Read more →
Meet Your Swap Dealer
Derivatives The CFTC has adopted final rules regarding business conduct standards for swap dealers. The rules are expected to have far reaching impacts on the way corporate counterparties... Read more →
CFTC Issues Final Internal Business Conduct Rules for Swap Dealers—Commissioners O’Malia and Sommers Are Not Impressed
Banking, Derivatives, Energy The CFTC approved four final rules (the “Internal Business Conduct Rules”) affecting duties of swap dealers (“SDs”) and major swap participants (“MSPs”) today, with... Read more →
CFTC Eliminates Key Exemption From Registration as a Commodity Pool Operator
Derivatives, Investment Advisers The CFTC has eliminated the exemption from registration as a commodity pool operator, or CPO, set forth in CFTC Rule 4.13(a)(4). The Rule provided an exemption from CPO... Read more →
Plaintiffs Challenging CFTC Position Limits Dealt Set Back
Derivatives, Litigation As we noted, the International Swaps and Derivatives Association, Inc., or ISDA, and the Securities Industry and Financial Markets Association, or SIFMA, filed a legal challenge... Read more →
CFTC Approves Final Rules Regarding Business Conduct Standards for Swap Dealers and Major Swap Participants
Banking, Derivatives, Energy The CFTC has approved its final rules regarding business conduct standards for swap dealers (“SDs”) and major swap participants (“MSPs”), which governs their dealings with... Read more →
CFTC Approves Final Regulations Regarding Registration of Swap Dealers and Major Swap Participants
Banking, Derivatives, Energy The CFTC has approved final regulations establishing a registration process for swap dealers (“SDs”) and major swap participants (“MSPs”), although the rule defining the... Read more →
CFTC Volker Rule Proposal is a Rube Goldberg Contraption
Banking, Derivatives The Commodity Futures Trading Commission, or CFTC, has proposed rules implementing the so-called “Volcker Rule” requirements of Section 619 of the Dodd-Frank Wall Street... Read more →

