Confirmations: NFA and CME’s Financial Match.com
Confirmations: Plugging Into Electronic Confirmations
CFTC Proposal Poses “Monumental” Challenge to FCMs
Daily Reports: Tell Us Where The Money Is
Customer Protection Fund: Slip it to SIPC
Customer Segregation: Keep It Separate
Cole-Frieman & Mallon partner/co-founder Bart Mallon Discusses CFTC Regulation 4.5, the Volcker Rule & Other Compliance Issues
Derivatives Attorney Jim Falvey Discusses the MF Global bankruptcy, the Volcker Rule & Compliance Issues Related to Dodd-Frank
This post is the next installment of a multi-part series on CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on February 20, 2024 (the “Proposed Rule”)....more
This post is an overview of the “one business day margin call requirement” that applies to separate account customers under CFTC Regulation §1.44, as proposed by the U.S. Commodity Futures Trading Commission (the “CFTC”) on...more
The previous post in this series discussed how different market participants hold different views of the relationship between an investment manager and its clients, particularly in the separate account context. That post...more
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
This is the third of a multi-part series (Introduction; Part 1) on a February 20 proposal by the U.S. Commodity Futures Trading Commission (“CFTC”) to implement CFTC Regulation §1.44 (the “Proposed Rule”) and related...more
In Short - The Situation: In a December 13, 2023, Open Meeting, the Commodity Futures Trading Commission proposed amendments to the Commission's regulations concerning clearing member funds held by a derivatives clearing...more
On November 3, 2023, the Commodity Futures Trading Commission (“CFTC”) proposed to significantly amend the rules on investment of customer funds by futures commission merchants (“FCMs”) and derivatives clearing organizations...more
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
The U.S. Securities and Exchange Commission (“SEC”) recently proposed amendments to its so-called custody rule[1] under the Investment Advisers Act of 1940 (“Advisers Act”). The Proposed Rule seeks to expand the range of...more
On April 14, by unanimous vote of the Commissioners, the Commodity Futures Trading Commission (“CFTC” or “Commission”) approved a notice of proposed rulemaking to update comprehensively its Part 190 Rules governing a...more
On July 27, 2016, the U.S. Commodity Futures Trading Commission (“CFTC”) proposed amendments to its rules (“Proposed Rules”) that loosen the conditions for exemption from registration as a futures commission merchant (“FCM”),...more