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CFTC Year in Review: 23 Takeaways From 2023 and Predictions for 2024

At an industry event in early 2023, Commodity Futures Trading Commission (CFTC or the Commission) Chairman Rostin Behnam set out a comprehensive agenda to include nearly three dozen rulemaking proposals as well as “business...more

CFTC Proposes Amendments to CPO, CTA Regulations

The Commodity Futures Trading Commission (CFTC or Commission) recently proposed amendments to CFTC Regulation 4.7 (the Proposed Rule) that would impact long-standing exemptions from certain compliance requirements for...more

COVID-19: CFTC Advances Regulatory Agenda Despite COVID-19 Pandemic

The Commodity Futures Trading Commission (CFTC or Commission) continues to advance its regulatory agenda amid the COVID-19 crisis. After an initial flurry of no-action letters that ameliorate compliance with a number of...more

New Joint Audit Committee Regulatory Alerts

On May 14, 2019, the Joint Audit Committee (JAC) issued two regulatory alerts calling for futures commission merchants (FCMs) to review policies and procedures and account agreements in situations where an FCM carries...more

SEC Adopts Rules on Non-US Firms That “Arrange, Negotiate, or Execute” Security-Based Swaps in the US

On Wednesday, the Securities and Exchange Commission (SEC) adopted rules that will affect firms operating in the global security-based swap market. Specifically, the SEC is requiring non-US firms that arrange, negotiate, or...more

CFTC Alert: 2015 CFTC Year-in-Review, and a Look Forward

CFTC continues to bring high-profile, large-penalty enforcement cases; begins bringing cases to enforce Dodd-Frank Act implementing regulations; and embarks on post-Dodd-Frank Act regulatory initiatives. ...more

CFTC Proposes “Regulation AT” for Automated Trading

I. Executive Summary - On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or...more

CFTC Updates Position Limits Rule

On September 22, 2015, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved the publication of a “supplemental” proposed rule on position limits. The supplemental proposal would modify the...more

SEC Proposes Rules to Oversee Non-US Firms’ Swap Activity in the United States

On April 29, 2015, the US Securities and Exchange Commission (SEC) proposed new rules to enhance its oversight of non-US firms’ security-based swap activity in the United States. The proposal, if adopted, will have important...more

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