CFTC Mandatory Clearing Rules - June 10 Phase-in Date for Financial Entities
Joshua Cohn,Curtis A. Doty,Pamela J. Sackmann, May 22, 2013
The next milestone date in the Commodity Futures Trading Commission’s (“CFTC’s”) phase-in of mandatory clearing occurs on June 10, 2013, when so-called “Category 2 entities” must begin clearing swaps subject to the mandate. Securitization vehicles, insurers,...

CFTC Provides Derivatives Prime Brokerage Limited No-action Relief from External Business Conduct Rules
Joshua Cohn,Curtis A. Doty, May 2, 2013
Today, compliance is required for the first time with previously deferred provisions of the swap dealer external business conduct rules of the Commodity Futures Trading Commission (the “Commission”). In response to market concerns regarding the potentially disruptive impact of the...

CFTC Issues a Final, Time-Limited Exemptive Order and Proposes Further Guidance Regarding Cross-Border Regulation of Swaps
Joshua Cohn,Curtis A. Doty,Jerome J. Roche,David R. Sahr,Donald S. Waack, January 2, 2013
On December 21, 2012, the US Commodity Futures Trading Commission (“CFTC”) issued a release (the “Release”) containing a final exemptive order (the “Order”) and proposing for public comment additional cross-border guidance (the “Further Proposed...