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...

CFTC’s January 1 Business Conduct and Documentation Deadline Eased
Chris Arnold,Joshua Cohn,Curtis A. Doty,Jerome J. Roche,David R. Sahr, December 20, 2012
The Commodity Futures Trading Commission (the “Commission”) today adopted interim final rules that defer the dates by which swap dealers (“SDs”) and major swap participants (“MSPs”) are required to comply with many provisions of the Commission’s external...