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,...

The ISDA March 2013 Dodd-Frank Protocol (the “DF Protocol 2.0”) is Open for Adherence
Joshua Cohn,Pamela J. Sackmann, May 20, 2013
On March 22, 2013, ISDA opened the DF Protocol 2.0 for adherence to market participants. The DF Protocol 2.0 is part of ISDA’s documentation initiative aimed at assisting the derivatives industry in implementing and complying with the regulatory requirements imposed under Title VII of the...

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...