Toward the end of 2014, the staff of the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO)
There has been considerable concern in the insurance and reinsurance industries that certain hedging and reinsurance activities that companies have
The Commodity Futures Trading Commission's (CFTC) Division of Swap Dealer and Intermediary Oversight (Division) recently addressed for the first time
On May 7th, the Commodity Futures Trading Commission ("CFTC") issued a time-limited no-action letter stating that the Division of Clearing and Risk
The CFTC has proposed for comment, CFTC Rule 170.17, which would require all IBs, CTAs and CPOs become members of a registered futures association
The Dodd-Frank Act’s expansion of the definition of “commodity pool” to include any form of enterprise operated for the purpose of trading in “swaps,” coupled with the Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”) recently adopting an expansive definition of the term “swap” for purposes of the Dodd-Frank Act and the Commodity Exchange Act, creates uncertainty regarding whether issuers of insurance linked securities (“ILS”) are commodity pools that would require the registration of commodity pool operators (“CPO”) and commodity trading advisors (“CTA”) with the CFTC.
The SEC and CFTC Voted to Further Define “Swap”, “Security-Based Swap”, and “Security-Based Swap Agreement” and Finalize Related Requirements; CFTC Finalizes End-User Exception.
On April 27, 2011, the Securities and Exchange Commission ("SEC") and the Commodity Futures Trading Commission ("CFTC") (collectively, the "Commissions") issued joint proposed rules and interpretive guidance (the "Proposed Rules") to further define and solicit public comment on the terms "swap," "security-based swap," and "security-based swap agreement.
The Dodd-Frank Act imposes considerable new requirements on the business of derivatives, including, among others, rules concerning clearing and settlement, margin requirements, capital requirements, reporting and position limitations.
On April 27, 2011, the Commodity Futures Trading Commission ("CFTC") and the Securities and Exchange Commission ("SEC") jointly issued proposed rules and proposed interpretive guidance further defining key terms with respect to the regulation of derivatives under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act.