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Commodities Futures Trading Commission No-Action Letters

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - February 2024 - 2

Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Carlton Fields

Fifth Circuit Breaks From No-Action Pack: Becomes Better Bet for Letter Recipients?

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On July 21, 2023, a three-judge panel of the Fifth Circuit Court of Appeals issued an opinion asserting that the Commodity Futures Trading Commission’s Division of Market Oversight likely acted arbitrarily and capriciously,...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - September 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Butler Snow LLP

Sometimes no decision is the decision: Parties must protect themselves when a court does not timely rule on a motion for...

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We’ve all been in a position where we make an ask of someone—whether it be a significant other, a colleague, a potential client—and you don’t hear back from them. Maybe you ask if they want to attend a concert, write a blog...more

WilmerHale

CFTC 2022 Enforcement and Regulatory Developments and a Look Forward

WilmerHale on

The year 2022 was a historic year for the Commodity Futures Trading Commission (“CFTC” or the “Commission”). Just four days into the new year, on January 4, 2022, Rostin Behnam was sworn in as the CFTC’s 15th Chairman. Three...more

Cadwalader, Wickersham & Taft LLP

Unpredictable Future of Political Prediction Markets

On August 4, the U.S. Commodity Futures Trading Commission (“CFTC”) had withdrawn its no-action letter (i.e., permission to operate) with respect to PredictIt, an online prediction market operated by the University of...more

Akin Gump Strauss Hauer & Feld LLP

CFTC Staff Extends Relief with Respect to Certain Position Limit Aggregation Requirements

Key Points - Until August 12, 2025, CPOs and CTAs may continue to file position limit disaggregation notices upon request, rather than prospectively, and exempt CTAs may continue to rely upon the “independent account...more

Latham & Watkins LLP

2020 Digital Asset Regulatory Lookback (US Edition)

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Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. Last year, Latham & Watkins sounded a hopeful note that 2020 would provide...more

Orrick, Herrington & Sutcliffe LLP

Extension of Brexit No-Action Letters

In November 2020, the CFTC published two no-action letters extending previously granted no-action relief related to Brexit. The relief was intended to provide “greater certainty to the global marketplace” in connection with...more

Orrick, Herrington & Sutcliffe LLP

CFTC Issues Brexit-Related No-Action Relief Regarding Margin and Clearing Requirements

The CFTC recently published Brexit-related Letter No. 20-42 (December 4, 2020) in response to a request from the International Swaps and Derivatives Association, Inc. (ISDA). In its request, ISDA stated that the expiration of...more

Morrison & Foerster LLP

Consumer Financial Pilot Advisory Opinion Program Takes Flight

On June 22, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) published two notices in the Federal Register announcing (1) the launch of a pilot advisory opinion (AO) program (“Pilot AO Program”); and (2) a...more

Bass, Berry & Sims PLC

Chris Lazarini Reviews Anti-Manipulation Provision of the Commodity Exchange Act

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Bass, Berry & Sims attorney Chris Lazarini reviewed a case in which a putative class of individuals that transacted certain Korean futures contracts on the Korea Exchange through the Chicago Mercantile Exchange’s Globex...more

Morgan Lewis

CFTC Issues Additional Relief in Response to COVID-19

Morgan Lewis on

The US Commodity Futures Trading Commission recently issued more no-action letters in response to the coronavirus (COVID-19) pandemic, providing relief from capital requirements and fingerprint requirements....more

Alston & Bird

CFTC Issues No-Action Letter Offering Regulatory Relief for CPOs

Alston & Bird on

Our Investment Management Team outlines how the Commodity Futures Trading Commission will allow commodity pool operators to delay their reporting obligations during the coronavirus pandemic....more

WilmerHale

Coronavirus COVID 19 CFTC and NFA Issue Relief and Guidance

WilmerHale on

The Commodity Futures Trading Commission (CFTC or Commission) has issued a series of eight staff letters which will facilitate the functioning of the derivatives markets during the COVID-19 pandemic. These actions will assist...more

A&O Shearman

CFTC Staff Issues Three Letters Providing LIBOR Transition Relief to Market Participants

A&O Shearman on

The Commodity Futures Trading Commission (CFTC) has issued three no-action letters providing relief for swap transactions (and amendments to swap transactions) in connection with the expected market transition from using the...more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

Goodwin on

In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Illusory Promise or Real Change? Transition at CFTC Brings Hope for Dodd-Frank Act Revisions

Over the past five years, the Commodity Futures Trading Commission (CFTC) has settled 20 enforcement actions against financial institutions for violations of various Dodd-Frank Act regulatory requirements (i.e., rules other...more

Morrison & Foerster LLP

CFTC Issues No-Action Letters To Smooth The Road Away From The IBORs

On December 17, 2019, three different divisions of the Commodity Futures Trading Commission (“CFTC”) issued no-action letters intended to facilitate the swaps market’s transition away from interbank offered rates (each, an...more

Cadwalader, Wickersham & Taft LLP

CFTC Codifies Registration and Reporting Relief for Commodity Pool Operators and Commodity Trading Advisors

The Commodity Futures Trading Commission (the “CFTC”) approved the publication of two releases (the “Final Rules”) on November 25, 2019, adopting final amendments to Part 4 of the CFTC Rules which codify and expand a number...more

Goodwin

Financial Services Weekly News: Regulators Prepare for End of LIBOR

Goodwin on

I’m Dreaming of . . . LIBOR Cessation and Transition. While many of us were enjoying the holiday season, federal and state financial regulators were focused on the transition away from the London Interbank Offered Rate...more

Polsinelli

Wind of Change - The Year FinTech Came in From the Cold - Polsinelli BitBlog: Year End Edition

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Digital assets and Blockchain technologies which were once described as the tools of criminals, are now a key part of efforts by traditional financial services firms to transform their businesses and innovative firms looking...more

Eversheds Sutherland (US) LLP

BDCs must reclaim relief from CPO registration

On November 25, 2019, the Commodity Futures Trading Commission (CFTC) adopted several final regulations to codify existing exemptions from commodity pool operator (CPO) registration. Among them is an exemption that was issued...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on a Number of SEC Proposals Related to Shareholders and Proxy Voting...

SEC/CORPORATE - SEC Proposes New Amendments to Modernize Shareholder Proposal Rules - On November 5, the Securities and Exchange Commission voted to propose amendments to Rule 14a-8 of the Securities Exchange of 1934...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on SEC's Changes to Rule 14a-8 No-Action Request Process, FINRA's Call for...

SEC/CORPORATE - SEC Staff Announces Changes to Rule 14a-8 No-Action Request Process - On September 6, the staff of the Division of Corporation Finance (the Staff) of the Securities and Exchange Commission announced...more

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