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Swap Dealers › Reporting Requirements

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
Orrick, Herrington & Sutcliffe LLP

CFTC orders bank to pay $5M for swap reporting violations

Orrick, Herrington & Sutcliffe LLP on

On August 26, the CFTC issued an order against a bank for allegedly failing to correctly report millions of swap transactions to a registered swap data repository, in violation of a prior CFTC order, and for failing to...more

Cadwalader, Wickersham & Taft LLP

CFTC’s Recent Revisions to Reporting Rules for Futures, Options and Swaps

Cadwalader, Wickersham & Taft LLP on

On April 30, 2024 the Commodity Futures Trading Commission (“CFTC” or the “Commission”) finalized amendments to its rules governing reporting requirements for large trader futures and options positions, the latest in a series...more

Katten Muchin Rosenman LLP

The CFTC Adopts Amendments to Capital and Financial Reporting Requirements for Swap Dealers Largely Based on Prior Relief

Katten Muchin Rosenman LLP on

After adopting final rules in 2020, the Commodity Futures Trading Commission (CFTC) adopted amendments to the capital and financial reporting requirements for Swap Dealers (SDs), which were largely based on prior no-action...more

Davis Wright Tremaine LLP

CFTC Finalizes Two Sets of Reporting Requirements

Davis Wright Tremaine LLP on

Updated: reporting requirements for swap dealers, swap participants, and large traders in the futures and options market On April 30, 2024, in two separate releases, the Commodity Futures Trading Commission ("CFTC")...more

Cadwalader, Wickersham & Taft LLP

CFTC Finalizes Rule Regarding LIBOR Transition Clearing Requirement Determination for Certain Interest Rate Swaps

Cadwalader, Wickersham & Taft LLP on

On August 12, the Commodity Futures Trading Commission (“CFTC”) issued a final rule amending its Regulation 50.4(a) clearing requirements for swaps. The latest in a series of rulemaking that is supportive of the...more

Cadwalader, Wickersham & Taft LLP

CFTC’s Swap Reporting Advisory

Cadwalader, Wickersham & Taft LLP on

Accurate and timely reporting of swap data is the cornerstone of swap regulation. The CFTC had promulgated its swap reporting rules in 2012, and were after 2012 among the first rules implementing the Dodd-Frank Act to...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Morgan Lewis

CFTC Amends Real-Time Swap Public Reporting Requirements

Morgan Lewis on

The Commodity Futures Trading Commission (CFTC) has unanimously approved amendments to the real-time swap reporting rules in Part 43 of the CFTC’s regulations by, among other things, clarifying the applicability of the rules...more

Orrick - Finance 20/20

CFTC Approves Final Swap Dealer Capital Rule

Orrick - Finance 20/20 on

On July 22, the Commodity Futures Trading Commission (CFTC) approved a final rule regarding new capital and financial reporting requirements for swap dealers and major swap participants that are not subject to supervision by...more

Stoel Rives - Renewable + Law

CFTC Proposed Rule Benefits Certain Financially-Settled Offtake Arrangements

Stoel Rives - Renewable + Law on

On February 20, 2020, the Commodity Futures Trading Commission (CFTC) unanimously approved a proposed rule that would revise certain reporting requirements for financially-settled offtake contracts that qualify as “swaps”...more

WilmerHale

The SEC's Security-Based Swap Recordkeeping and Reporting Rules

WilmerHale on

On September 19, 2019, the Securities and Exchange Commission (SEC or Commission) adopted new rules and amendments establishing recordkeeping and reporting requirements for security-based swap dealers (SBSDs), major...more

Orrick - Finance 20/20

CFTC Issues Advisory Regarding Chief Compliance Officer Annual Report Requirements

Orrick - Finance 20/20 on

On December 4, the CFTC issued an advisory (Staff Advisory 19-24) providing further guidance on certain requirements applicable to swap dealers, futures commission merchants and major swap participants (collectively,...more

Katten Muchin Rosenman LLP

Bridging the Weeks - October 2019

Katten Muchin Rosenman LLP on

Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more

Orrick - Finance 20/20

SEC Adopts New Rules and Amendments Under Title VII of Dodd-Frank

Orrick - Finance 20/20 on

On September 19, the SEC adopted new rules and amendments under Title VII of the Dodd-Frank Act establishing recordkeeping and reporting requirements for security-based swap dealers and major security-based swap participants,...more

WilmerHale

CFTC Proposes Additional Swap Data Reporting Requirements

WilmerHale on

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

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Proposes Sweeping Swap Reporting Amendments Aimed at Improving Data Accuracy and Completeness

Skadden, Arps, Slate, Meagher & Flom LLP on

On April 25, 2019, the Commodity Futures Trading Commission (CFTC or Commission) published for public comment proposed amendments to the rules governing swap data repositories (SDRs) and reporting obligations of swap market...more

Katten Muchin Rosenman LLP

Bridging the Week - November 2018 #2

Katten Muchin Rosenman LLP on

A swap dealer was fined US $12 million by the Commodity Futures Trading Commission for a host of purported noncompliance issues. It was also sanctioned for allegedly not disclosing in two annual chief compliance officer...more

Morrison & Foerster LLP

CFTC Amends Chief Compliance Officer Duties and Annual Report Requirements

Morrison & Foerster LLP on

On August 27, 2018, the Commodity Futures Trading Commission (“CFTC”) published final rules in the Federal Register amending its regulations regarding duties of chief compliance officers (“CCOs”) of swap dealers (“SD”), major...more

Morrison & Foerster LLP

CFTC Chairman Issues White Paper Outlining Agenda for Changes to Swaps Regulation

Morrison & Foerster LLP on

On April 26, 2018, J. Christopher Giancarlo, Chairman of the Commodity Futures Trading Commission (“CFTC” or “Commission”) and Bruce Tuckman, the CFTC’s Chief Economist, issued a white paper outlining changes to swaps...more

A&O Shearman

A Corporate End User’s Handbook for Dodd-Frank Derivatives Compliance

A&O Shearman on

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), signed into law on July 21, 2010, was the largest overhaul of the U.S. derivatives market in history. While there are still a few parts of Dodd-Frank...more

Orrick - Finance 20/20

CFTC Staff Grants Time-Limited Extension of Swap Data Reporting Relief for Certain Swap Dealers and Major Swap Participants...

Orrick - Finance 20/20 on

On November 30, 2017, the U.S. Commodity Futures Trading Commission‘s (“CFTC“) Division of Market Oversight announced in a no-action letter that it had extended relief it provided certain CFTC-registered swap dealers (“SD“)...more

A&O Shearman

National Futures Association Simplifies Section 4s Submission and Review Process for Swap Dealer Registration

A&O Shearman on

On July 24, 2017, the National Futures Association (“NFA”) adopted measures to streamline the process for registration of swap dealers pursuant to Section 4s of the Commodity Exchange Act. Previously, entities seeking to...more

Morrison & Foerster LLP

CFTC Proposes to Amend Chief Compliance Officer Duties and Annual Report Requirements

Morrison & Foerster LLP on

On May 3, 2017, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to its rules regarding the duties of Chief Compliance Officers (“CCOs”) for swap dealers...more

Stinson - Corporate & Securities Law Blog

CFTC Proposes Amendments to Chief Compliance Officer Duties and Annual Reports

Stinson - Corporate & Securities Law Blog on

The CFTC is proposing to amend its regulations regarding certain duties of chief compliance officers, or CCOs, of swap dealers, major swap participants and futures commission merchants, which are referred to as registrants....more

A&O Shearman

US Commodity Futures Trading Commission Approves Rule Amending Chief Compliance Officer Annual Report Timing for Certain...

A&O Shearman on

The US Commodity Futures Trading Commission announced its unanimous approval of a final rule amending CFTC regulation 3.3 to provide for a 90-day window after the end of an institution’s fiscal year for the filing of chief...more

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