Stephen R. Morris

At Last . . . the CFTC Proposes to Codify Letter 19-17

USA - March 16 2023 The CFTC has proposed rules codifying the staff no-action relief of CFTC Letter 19-17 (thrice-renewed since, pending these rules). I’ve written about…

FCMs are Custodians: The SEC's Proposed Safekeeping Rule Will Present Challenges for Them

USA - March 2 2023 Much has been, and remains to be, written on the SEC’s recent proposal to replace the custody rule for registered investment advisers with a new…

Broker-dealer/FCMs! You need to have a talk with your clients about AEX Index Futures

USA - February 8 2023 Last month, Euronext published a notice to clients that will be of interest to US broker-dealers and FCMs who facilitate client execution and…

The Unprecedented Events of March: The Oliver Wyman Report

USA - February 6 2023 Thankfully, futures clearinghouses do not fail often; it’s happened three times in history, most recently in 1987. But last year, in the first week of…

Jacob Setton

Lessons for FCM Risk Managers from a Recent CFTC Enforcement Settlement

USA - December 27 2022 Recently the CFTC settled an administrative proceeding with an FCM that FCM risk managers will want to examine closely…