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Kenneth M. Raisler Document Search Results (3)
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CFTC Staff Clarifies Scope of Swap Definition: CFTC’s Office of General Counsel Responds to Questions Regarding Certain Physical Commercial Agreements
David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article
November 16, 2012
, previously published on November 15, 2012
On November 14, 2012, the Officer of the General Counsel (the “OGC”) of the Commodity Futures Trading Commission (the “CFTC”) issued a response to frequently asked questions (the “FAQ”) in which it clarified the scope of the definition of the term...
Clearing Exemption for Inter-Affiliate Swaps: CFTC Proposes Rule to Exempt Swaps between Certain Affiliated Entities from the Clearing Requirement under Dodd-Frank
David J. Gilberg, Kenneth M. Raisler; Sullivan & Cromwell LLP;
Legal Alert/Article
September 5, 2012
, previously published on September 4, 2012
On August 16, 2012, the CFTC issued a proposed rule to exempt swaps between certain affiliated entities within a corporate group from the clearing requirement imposed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Dodd-Frank amended the Commodity Exchange Act (CEA)...
CFTC Guidance on Extraterritoriality: CFTC Releases Proposed Guidance on and Exemptive Relief from Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act
David J. Gilberg, Eric J. Kadel, Kenneth M. Raisler, Dennis C. Sullivan, Andrea R. Tokheim; Sullivan & Cromwell LLP;
Legal Alert/Article
July 14, 2012
, previously published on July 12, 2012
On June 29, 2012, the Commodity Futures Trading Commission (“CFTC”) issued proposed guidance (“Proposed Guidance”) on the cross-border application of certain swaps provisions under the Commodity Exchange Act (“CEA”) and a proposed exemptive order (“Proposed...
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