Staff of the Commodity Futures Trading Commission (CFTC) has issued an Interpretation permitting futures commission merchants (FCMs) to deposit US customer funds margining foreign futures and options positions with UK investment firms that are licensed deposit-taking banks as bank deposits. CFTC customer protection rules Part 30 of the CFTC’s regulations governs the offer and sale … Continue Reading
During an otherwise quiet Summer at the Commodity Futures Trading Commission (CFTC), agency staff hosted a public Roundtable where commercial end-users and other market participants could comment on the CFTC’s re-proposed rules to implement the position limits and aggregation provisions of the Dodd-Frank Act. The common theme from end-users was that the CFTC’s proposals would … Continue Reading
Staff of the Commodity Futures Trading Commission (CFTC) has issued a no-action letter to swap execution facilities (SEFs), through September 30, 2015, if a SEF: 1) incorporates by reference the terms of underlying previously-negotiated agreements between swap counterparties in its confirmation without receiving copies of those agreements by the time the trade is executed; or … Continue Reading
On August 19, 2014, Rick A. Fleming, the head of the Office of the Investor Advocate of the Securities and Exchange Commission (the “SEC”), gave a speech at the 38th Annual Southwest Securities Conference, in which he urged Congress to authorize the SEC to collect an annual “user fee” from registered investment advisers that would … Continue Reading