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 Approves Final Rules Regarding Business Conduct Standards for Swap Dealers and Major Swap Participants

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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 counterparties generally and imposes additional requirements to their dealings with Special Entities (which include governmental entities, certain employee benefit plans under ERISA, and endowments). The rules prohibit certain... Read more →

by Nate Endrud   |   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 Nate Endrud   |   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 Nate Endrud   |   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 Nate Endrud   |   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 Nate Endrud   |   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 Steve Quinlivan   |   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 Nate Endrud   |   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 Nate Endrud   |   May 5, 2011

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CFTC Provides Guidance on Exclusion of Forward Contracts from Definition of “Swap”

Banking, Derivatives, Energy In its joint proposed rule and guidance on product definitions with the SEC, the CFTC has provided guidance on the exclusion of forward contracts (with respect to nonfinancial... Read more →

by Nate Endrud   |   May 1, 2011

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CFTC Proposes Capital Requirements for Swap Dealers and Major Swap Participants

Banking, Derivatives, Energy Complementing its recently proposed rules establishing margin requirements for swap dealers (SDs) and major swap participants (MSPs), the CFTC proposed rules regarding capital... Read more →

by Nate Endrud   |   April 28, 2011