Extension of comment period on SEC capital and margin rules *

USA - February 19 2013
On October 18, 2012, the Securities and Exchange Commission (the "SEC") issued Release No. 34-68071 containing its proposed rules (the "Proposed…

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Deferral of the swaps push-out requirement, but only for insured federal depository institutions *

USA - January 11 2013
An insured federal depository institution may request a transition period to comply with the "push-out" requirements of section 716 of the Dodd-Frank…

Co-authors: Ernest T. Patrikis, Duane D. Wall.

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Final exemptive order regarding compliance with certain swap regulations; further proposed guidance *

USA - January 3 2013
On December 21, 2012, the Commodity Futures Trading Commission (the "Commission" or "CFTC") approved an exemptive final order (the "Final Order")…

Co-authors: Claire Hall, Yvette Valdez, Steven K. Ross.

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The CFTC issues interim final rules extending the time for compliance for certain business conduct and documentation requirements for swap dealers and major swap participants *

USA - December 21 2012
On December 18, 2012, the US Commodity Futures Trading Commission's (the "Commission") approved interim final rules (the "Interim Final Rules")1 for swap…

Co-authors: Claire Hall, Yvette Valdez.

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The CFTC and the Division of Swap Dealer and Intermediary Oversight publishes a series of no-action letters, Q&As and FAQs *

USA - November 29 2012
In the space of a few days in mid-October, the Commodity Futures Trading Commission (the “CFTC”) published a number of Q&As and FAQs and the CFTC staff at the Division of Swap Dealer and Intermediary Oversight (the “Division”) and the Office of General Counsel (“OGC”) published several interpretative and no-action letters.

Co-authors: Claire Hall, Stuart Willey, Yvette Valdez, David Barwise, Steven K. Ross.

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