Dodd-Frank Energy
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 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 →
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 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 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 →
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 →
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 →
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 →
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 →
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 →

