CFTC Eliminates Certain Trade Option Reporting and Recordkeeping Requirements for End Users


The CFTC approved a final rule today that removes trade option* reporting and recordkeeping requirements applicable to non-swap dealer/major swap participant counterparties (“Non-SD/MSPs” or “end users” for purposes of this summary). The rule will become effective upon publication in the federal register, which should occur prior to the April 1,... Read More

Topics: Derivatives, Energy

CFTC Provides Delivery Method for Volcker Rule CEO Attestation


The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission, or CFTC, announced that certain banking entities subject to Appendix B of Part 75 of the Commission’s regulations should submit their CEO attestations through the following email address: Part 75 of the CFTC’s regulations implements... Read More

Topics: Derivatives to Sell Securities Using Bitcoin Blockchain Technology

By has filed this Form S-3 which proposes to sell securities using Bitcoin blockchain technology.  The S-3 has not yet been declared effective. First question: What the heck in blockchain technology?  CFTC Commissioner J. Christopher Giancarlo described it as follows: “The 20th century underpinnings of the current “closed ledger” financial system are... Read More

Topics: Banking, Broker-Dealer, Derivatives, Public Companies and Securities

FAST Act Fixes Dodd-Frank Swap Glitch


Although primarily a transportation bill, the FAST Act contains other provisions, including provisions simplifying securities laws and another provision fixing the Dodd-Frank Act.  As describe by CFTC Commissioner J. Christopher Giancarlo “The Dodd-Frank Act created the vehicle of swap data repositories to compile data on global swaps transactions providing international... Read More

Topics: Derivatives

CFTC Moves Against Bitcoin Transactions


In the space of just seven days, the CFTC has brought two enforcement actions regarding Bitcoin transactions. Coinflip, Inc. In the first action, the CFTC issued an order filing and simultaneously settling charges against Coinflip, Inc. d/b/a Derivabit and its chief executive officer for conducting activity related to commodity options... Read More

Topics: Derivatives, Litigation