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David J. Gilberg Document Search Results (7) Sort by:  | CFTC Proposes Aggregation Exemptions: Proposal Would Expand Exemptions from Aggregation under the New Position Limit Rules, Including For Non-Majority Investments
Whitney A. Chatterjee, David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article May 24, 2012, previously published on May 21, 2012 On October 18, 2011, the Commodity Futures Trading Commission (the “CFTC”) adopted final position limit rules (the “Position Limit Rules”). The Position Limit Rules establish Part 151 of the CFTC’s Regulations, which will impose spot- and non-spot-month limits...
| | CFTC Adopts Internal Business Conduct Rules
David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article March 19, 2012, previously published on March 8, 2012 On February 23, 2012, the Commodity Futures Trading Commission voted to adopt final rules that regulate the internal conduct of futures commission merchants, introducing brokers, swap dealers and major swap participants. These rules impose duties and restrictions on these categories of registered...
| | CFTC Proposes Block Size Rules for Swaps: CFTC Proposes Procedures to Establish Appropriate Minimum Block Sizes for Block Trades and Large Notional Off-Facility Trades
David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article March 16, 2012, previously published on March 12, 2012 Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) added Section 2(a)(13)(A) to the Commodity Exchange Act (the “CEA”), which requires the Commodity Futures Trading Commission (the “CFTC” or the “Commission”) to...
| | CFTC Adopts Final Rule Amendments Regarding Registration and Reporting Requirements for CPOs and CTAs and Issues Regulatory Harmonization Proposal
Whitney A. Chatterjee, Donald R. Crawshaw, David J. Gilberg, Eric J. Kadel, Kenneth M. Raisler, Dennis C. Sullivan; Sullivan & Cromwell LLP;
Legal Alert/Article February 24, 2012, previously published on February 22, 2012 On February 9, 2012, the CFTC adopted rule amendments that will, among other things, require registration of certain entities that are currently eligible for exemptions from registration as CPOs and CTAs. The February 9, 2012 adopting release (the “Adopting Release”) implements, with...
| | CFTC Adopts Final Rules on Business Conduct Standards: CFTC Imposes External Business Conduct Standards on Swap Dealers and Major Swap Participants
David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article February 8, 2012, previously published on February 6, 2012 The Commodity Futures Trading Commission (the “Commission” or “CFTC”) adopted final rules on the Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties (the “External Business Conduct Rules” or “Final Rules”). The...
| | CFTC to Impose Position Limits on Derivatives on 28 Physical Commodities: CFTC Issues Final Rules to Impose Position Limits on Physical Commodity Futures, Options, Swaps and Swaptions
Whitney A. Chatterjee, David J. Gilberg, Kenneth M. Raisler, Dennis C. Sullivan; Sullivan & Cromwell LLP;
Legal Alert/Article November 10, 2011, previously published on November 7, 2011 The Commodity Futures Trading Commission (“CFTC”) adopted interim and final rules on positions limits applicable to option, futures, swap and swaption contracts related to 28 agricultural, metal and energy commodity contracts (the “Final Rules”). The Final Rules impose...
| | SEC Exemptive Relief in Connection with Effective Date of Title VII of Dodd-Frank: SEC Issues Interim Final Rules and Order to Provide Relief from Certain Provisions That Would Be Effective on July 16, 2011
Whitney A. Chatterjee, David J. Gilberg, Eric J. Kadel, Kenneth M. Raisler, Robert W. Reeder, Robert S. Risoleo, Dennis C. Sullivan; Sullivan & Cromwell LLP;
Legal Alert/Article July 18, 2011, previously published on July 8, 2011 On July 1, the Securities and Exchange Commission issued interim final rules and an order providing temporary relief from certain requirements of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to security-based swaps (“SBS”) that would otherwise...
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