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CFTC issues proposed interpretive order on disruptive trading practices

Leonard, Street and Deinard
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USA
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March 3 2011

Section 747 of the Dodd-Frank Act prohibits three "disruptive" trading practices and grants the CFTC authority to enforce the prohibitions

CFTC provides guidance on exclusion of forward contracts from definition of “swap”

Leonard, Street and Deinard
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USA
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May 1 2011

In its joint proposed rule and guidance on product definitions with the SEC, the CFTC has provided guidance on the exclusion of forward contracts (with respect to nonfinancial commodities) from the definition of the term "swap," which finds its statutory authority in the Dodd-Frank Act's exclusion of "any sale of a nonfinancial commodity or security for deferred shipment or delivery, so long as the transaction is intended to be physically settled."

CFTC approves final rule on end-user exception

Leonard, Street and Deinard
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USA
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July 13 2012

The CFTC has approved its final rule on the so-called “end-user exception” to the Dodd-Frank Act’s mandatory clearing requirement applicable to swaps required to be cleared (roughly, standardized swaps

ISDA publishes Dodd-Frank protocol to facilitate compliance

Leonard, Street and Deinard
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USA
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August 19 2012

The International Swaps and Derivatives Association, Inc. (ISDA) has announced the launch of the August 2012 Dodd-Frank Protocol

Deadline approaches for energy company swap reporting

Leonard, Street and Deinard
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USA
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March 18 2013

The CFTC's Dodd-Frank swap reporting and recordkeeping requirements become mandatory on April 10, 2013, for all persons and companies engaging in

CFTC no-action letter allows most end users to report all trade options on annual aggregate basis

Leonard, Street and Deinard
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USA
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April 7 2013

The CFTC Division of Market Oversight (DMO) has issued a no-action letter that will allow most swaps end users to report all trade options on an

President Obama’s CFTC budget includes “user fees” on derivative transactionscommissioners join the fray

Leonard, Street and Deinard
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USA
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February 15 2011

CFTC Commissioners Scott O'Malia (R) and Bart Chilton (D) have joined the fray over President Obama's recently released budget for fiscal year 2012 by releasing statements in recent days regarding the budget's allocation for CFTC spending

CFTC and bank regulators propose capital & margin rules for swap dealers and major swap participants

Leonard, Street and Deinard
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USA
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April 13 2011

Yesterday the CFTC and a group of "prudential regulators" proposed rules regarding capital and margin requirements for uncleared swaps entered into by swap dealers (SDs) and major swap participants (MSPs) (see discussion of proposed rule on SD and MSP definitions here

CFTC issues final internal business conduct rules for swap dealersCommissioners O’Malia and Sommers are not impressed

Leonard, Street and Deinard
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USA
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February 23 2012

The CFTC approved four final rules (the “Internal Business Conduct Rules”) affecting duties of swap dealers (“SDs”) and major swap participants (“MSPs”) today, with Chairman Gensler and Commissioners Chilton and Wetjen voting in support of the rules over pointed dissents of Commissioners O’Malia and Sommers

Swap rulemakingsCFTC & SEC hit the starting blocks

Leonard, Street and Deinard
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USA
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August 14 2010

As the CFTC's first move in its monumental task of implementing the swap trading provisions of Dodd-Frank, the agency yesterday announced a joint Advanced Notice of Proposed Rulemaking ("ANOPR") with the SEC seeking comments on the many critical definitions that will establish the scope of the agencies' jurisdiction and of important categories that will affect the level of regulation faced by companies trading energy swaps