Leonard Street and Deinard Dodd Frank

MAKING SENSE OF DODD-FRANK

The Dodd-Frank Act has broad and deep implications that will touch every corner of financial services and multiple other industries. This site, developed and maintained by attorneys at Leonard, Street and Deinard, is dedicated to making sense of this complex legislation and helping businesses understand how it will affect them specifically. Our Bloggers »

Dodd-Frank Energy

CFTC and SEC Approve Final Rule Defining “Swap Dealer”

Endrud.Nate.web

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 participant (“ECP”) in a joint rulemaking with the SEC (which voted 5-0 in favor of approval) that also defined the terms for “security-based” SDs and MSPs. The definition of the [...] Read more →

by   |   April 18, 2012

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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 →

by   |   February 23, 2012

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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 →

by   |   January 12, 2012

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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 →

by   |   January 11, 2012

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CFTC Issues Final Rule on Real-Time Swap Price Reporting

Banking, Derivatives, Energy The CFTC has approved its final rule on real-time reporting of swaps. This rule is intended to provide swap transaction and pricing data to the public on a real-time basis so as... Read more →

by   |   December 20, 2011

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CFTC Issues Final Rule on Swap Data Recordkeeping & Reporting

Banking, Derivatives, Energy The CFTC has approved its final rule on swap data recordkeeping and reporting, summarized below. RECORDKEEPING All persons transacting in swaps (as well as exchanges and clearing... Read more →

by   |   December 20, 2011

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CFTC Issues Final Rule on Position Limits

Derivatives, Energy The CFTC, by a 3-2 vote, has approved its final rule on position limits under the Dodd-Frank Act. Although the text of the rule has not been released, the Commission’s... Read more →

by   |   October 19, 2011

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CFTC: If Rule 10b-5 Works For the SEC, It Should Work For Us Too (And Maybe We’ll Win More Than One Case Every 35 Years)

Banking, Derivatives, Energy, Executive Compensation, Litigation The CFTC’s new anti-manipulation and anti-fraud rules are based on the SEC’s Rule 10b-5.  One CFTC Commissioner believes the new rule will end the CFTC’s nearly unanimous... Read more →

by   |   July 7, 2011

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CFTC Proposes to Postpone the Effective Date of Numerous Swap Trading Provisions

Banking, Derivatives, Energy The CFTC has proposed an order providing exemptive relief from various swap trading provisions of the Dodd-Frank Act that would otherwise go into effect on July 16, 2011 because... Read more →

by   |   June 15, 2011

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CFTC Reopens and Extends Comment Periods for Numerous Swap Rulemakings

Banking, Derivatives, Energy Noting that its proposed rules now provide a “substantially complete mosaic” of the regulatory framework for swaps under the Dodd-Frank Act, the CFTC has reopened and extended... Read more →

by   |   May 5, 2011