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ECP guarantor provisions in corporate credit agreements

Leonard, Street and Deinard
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USA
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April 29 2013

Many corporate credit agreements are supported by subsidiary guarantees. Those guarantees often include not only the guaranty of the obligations

CFTC Commissioners bicker about budget and performance report

Leonard, Street and Deinard
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USA
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April 12 2013

There continues to be significant public discord amongst the Commissioners at the CFTC. 2014 Budget; According to Commissioner Scott O’Malia “Given

CFTC approves final regulations governing exemption from required clearing for inter-affiliate swaps

Leonard, Street and Deinard
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USA
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April 1 2013

The CFTC has issued a final rule to exempt swaps between certain affiliated entities within a corporate group from the clearing requirement under the

CFTC provides relief for partial swap terminations

Leonard, Street and Deinard
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USA
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March 23 2013

The CFTC's Division of Clearing and Risk has issued a no-action letter that provides relief from required clearing for a limited set of "stub swaps"

CFTC’s initial attempts at data collection fail

Leonard, Street and Deinard
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USA
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March 21 2013

Since the beginning of 2013, the CFTC has required certain market participants to report their interest rate and credit index swap trades to a swap

CFTC reminds all swap counterparties of April 10 deadline to obtain a CICI identifier

Leonard, Street and Deinard
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USA
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March 20 2013

The Division of Market Oversight, or DMO, and Office of Data and Technology, or ODT of the CFTC have issued an advisory reminding all swap

CFTC grants relief to family offices from commodity pool operator rules

Leonard, Street and Deinard
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USA
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November 30 2012

The CFTC staff has issued a no-action letter regarding family offices

CFTC staff issues no-action letter addressing timeline for swap dealer compliance with swap data reporting rules

Leonard, Street and Deinard
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USA
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November 22 2012

CFTC staff have issued a letter providing swap dealers with time-limited no-action relief from certain requirements of the CFTC’s swap data reporting rules, which are set forth at Part 43, Part 45 and Part 46 of the CFTC’s regulations

Treasury issues foreign currency swap and forward exemption

Leonard, Street and Deinard
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USA
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November 21 2012

The Commodity Exchange Act, or CEA, as amended by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, authorizes the Secretary of the Treasury to issue a written determination that foreign exchange swaps, foreign exchange forwards, or both, should not be regulated as swaps under the CEA

CFTC provides no-action relief to swap dealers and major swap participants regarding certain recordkeeping obligations

Leonard, Street and Deinard
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USA
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October 29 2012

The CFTC has provided time-limited no-action relief for swap dealers, or SDs, and major swap participants, or MSPs, concerning certain recordkeeping obligations under Part 23 of the CFTC’s regulations