S. Chris Min

Orrick, Herrington & Sutcliffe LLP

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CFTC Extends No-Action Relief on the Applicability of Transaction-Level Requirements for Non-U.S. Swap Dealers

On August 13, 2015, CFTC Division of Swap Dealer and Intermediary Oversight, Clearing and Risk, and Market Oversight extended a time-limited no-action relief to swap dealers registered with the CFTC that are established under...more

8/24/2015 / CFTC , Commodity Exchange Act (CEA) , Financial Institutions , Financial Markets , No-Action Relief , Swap Dealers

CFTC Extends No-Action Relief to Swap Dealers and Major Swap Participants from Compliance with Reporting Obligations

On June 15, CFTC Division of Market Oversight published a letter extending the time-limited relief provided by previously issued no-action letter 14-90, expiring on June 30, 2015, to June 30, 2016. The relief applies to the...more

6/30/2015 / CFTC , Major Swap Participants , No-Action Letters , No-Action Relief , Swap Dealers , Swaps , Valuation

CFTC Staff Issues No-Action Relief Regarding CCO Annual Report Timing Requirement

On March 27, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to futures commission merchants, swap dealers and major swap participants from their obligation under...more

4/6/2015 / Annual Reports , CFTC , Chief Compliance Officers , DSIO , Futures Commission Merchants (FCMs) , Major Swap Participants , No-Action Relief , Reporting Requirements , Swap Dealers

CFTC Staff Issues No-Action Relief for Swaps with Legacy SPVs

On March 31, CFTC Division of Swap Dealer and Intermediary Oversight announced that it is providing no-action relief to provisionally registered swap dealers (SDs) from complying with certain specified regulations when...more

4/6/2015 / CFTC , DSIO , Legacy Funds , No-Action Relief , SPVs , Swap Dealers

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