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CFTC 2020 Enforcement and Regulatory Developments and a Look Forward

2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more

CFTC Ends 2019 with Rulemaking Flurry

The Commodity Futures Trading Commission (CFTC or Commission) at year-end issued one final and two proposed rulemakings. The proposed rules are potentially significant for all swap market participants, and the final rules are...more

The SEC Adopts Security-Based Swap Rules Governing Capital, Margin and Segregation

On June 21, 2019, the Securities and Exchange Commission (SEC or Commission) adopted a package of rules and rule amendments (Rules) that set forth the capital, margin and segregation requirements for security-based swap...more

CFTC Proposes Additional Swap Data Reporting Requirements

The Commodity Futures Trading Commission (CFTC) is proposing a significant, new reporting burden on swaps reporting parties and on swaps data repositories (SDRs). The proposal would impose new requirements on SDRs to verify...more

CFTC Announces Examination Priorities for 2019

On February 12, 2019, the Commodity Futures Trading Commission (CFTC or Commission) published for the first time its examination priorities for the coming year. The release of the priorities will provide legal and compliance...more

CFTC Proposes Three Rule Changes

Summary: The Commodity Futures Trading Commission (“CFTC” or “Commission”) on June 4, 2018, in its first public meeting of the year, proposed three rule changes to the rules implementing the Dodd-Frank Wall Street Reform and...more

Key Differences Between CFTC and SEC Final Business Conduct Standards and Related Cross-Border Requirements

The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more

Dodd-Frank Implementation Update: Key Differences Between the CFTC and SEC Final Business Conduct Standards and Related...

The Securities and Exchange Commission (SEC) recently adopted final business conduct rules for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) under Section 15F(h) of the Securities...more

Status of NFA's Section 4s Reviews and Swap Dealer Examinations

Beginning on December 31, 2012, swap dealers began filing applications for registration with the Commodity Futures Trading Commission (CFTC). As of October 2015, 104 entities are provisionally registered as swap dealers....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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