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Last week, the CFTC’s Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued time limited no-action relief to a regional commercial bank holding company and its insured depository institution (“IDI”) subsidiaries from having to count certain loan-related swaps toward its swap dealer de minimis threshold.  Currently,…
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The Center for Financial Stability is providing a freely accessible Financial Timeline, curated by Senior Fellow Yubo Wang.  The timeline, created in 2010 and actively maintained, charts more than 1,100 developments across the markets, institutions, the Federal Reserve, Treasury and other sources, from 2007 to the present.  This resource, which…
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The CFTC unanimously approved Final Rule amendments on August 21, 2018 to the regulations governing chief compliance officer (“CCO”) duties and annual compliance reporting requirements for FCMs, swap dealers and MSPs (“Registrants”). These amendments are the first substantive rule amendments to be adopted under Chairman Giancarlo’s…
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Our public memorandum here describes the notice of proposed rulemaking published by the CFTC on June 12, 2018 that would make permanent the $8 billion temporary swap dealer de minimis registration threshold currently in effect and would make other changes to the de minimis exception.

View as a PDF
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As we head into the July 4th holiday and the heart of summer approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals;…
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Financial services regulatory reform in 2018 continues to evolve.  For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,…
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As mid-year 2018 approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations and resignations and expiring terms.  The first slide summaries the state of play for the principals, and the later slides provide a deeper dive on an agency-by-agency…
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CFTC Chairman J. Christopher Giancarlo and CFTC Chief Economist Bruce Tuckman released a White Paper on April 26, 2018 that reflects the authors’ personal views on the need for swaps regulatory reforms in the United States in five key areas:

  1. swap execution on swap execution facilities (“SEFs”);
  2. trade

…
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Market participants are undertaking significant work to prepare for a transition away from LIBOR. This publication focuses on the legal framework and other issues related to fallback language. To give a more tangible sense of what may be at stake and the efforts required to transition, it provides in-depth analyses…
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A Cryptocurrency and DLT Newsletter – April 5, 2018

Authored by Jai R. Massari, Christophe Perchet, Byron B. Rooney, Daniel Arroche, Trevor I. Kiviat, Daniela Dekhtyar-McCarthy and Andrew Ruben

Market Developments

Web Platforms Continue to Ban ICO-Related Advertisements

The SEC increasingly is focusing its enforcement authority not only on companies…
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